Factors Influencing Adoption Of Wireless Technologies: Key Policy Issues, Barriers And Opportunities For People With Disabilities

ABSTRACT

While wireless communication and other information linked technologies have rapidly achieved widespread levels of adoption, a significant array of stakeholder groups have been effectively excluded, not as much by active intent as by inadvertent oversight and lack of awareness. Many of these technologies routinely used by the general population are frequently inaccessible to persons with disabilities. Barriers to the use of these technologies by people with varying disabilities may be subtle, but never the less very real. Public policy plays an important if frequently overlooked role for people with disabilities, in part because “people with disabilities…interface with so many different components of public policy systems, many of which are conflicting or inconsistent, such as employment goals and requirements for income assistance programs. The larger public policy context for disability and rehabilitation research reflects interlinking service delivery systems in which changes in one system often have a substantial impact on others.” (NIDRR, 1999). This paper presents preliminary results of policy research designed to develop a framework for assessing the status quo, developing inclusive policy initiatives, and evaluating the efficacy of the research approach.

INTRODUCTION

Mobile wireless information and communication technologies are rapidly emerging as an important medium to send and receive data, text, voice and video. Many routine daily activities – such as making doctor’s appointments, calling home, obtaining directions and purchasing goods and services – already rely on existing telecommunication tools. New wireless technologies will permit cell phones, and portable or wearable computers to function as universal remote consoles for accessing information and services and controlling appliances and devices. For example, a personal digital assistant may be used to conduct financial transactions, program a VCR, set a home thermostat, check the coffee pot, or locate and schedule public transportation. In short, wireless devices are becoming an integral part of daily life, and without access to these technologies, people with disabilities may find themselves increasingly excluded from many activities. Public policy plays an important if frequently overlooked role for people with disabilities, in part because “people with disabilities…interface with so many different components of public policy systems, many of which are conflicting or inconsistent, such as employment goals and requirements for income assistance programs. The larger public policy context for disability and rehabilitation research reflects interlinking service delivery systems in which changes in one system often have a substantial impact on others. The dilemma for disability and rehabilitation policy is that the various systems are not mutually reinforcing.” (NIDRR, 1999)

Given the key role of the public sector in directly shaping, and indirectly influencing the deployment of and access to these technologies, research focused on assessment and development of policy frameworks needs to be undertaken with respect to the regulatory and legal environment A wide array of linked policy areas are included in the assessment: 1) wireless and other information and communication technologies, 2) Disability policy, including the changing paradigms in provision of services to people with disability, 3) legal issues: professional licensure and liability, safety and standards; 4) privacy, security, and confidentiality; in that many technological approaches can come at the risk of loss of personal privacy; 5) device/user interfaces and capacity; and 6) applicability of policy initiatives to advance universal design to improving access to technology by people with disabilities. The goal of this research project is to develop a framework and a process for evaluating, developing and initiating policies, rules and regulations that support increased access to wireless information and communication technologies by people with disabilities.

METHODOLOGY

There are four phases to this project. The first phase, the baseline policy assessment reported on in this paper, involved the collection and analysis of existing, proposed, and developing wireless communication and information technologies, policies and practices as they impact on persons with disabilities. Key tasks include 1) reviewing Federal and state regulations and policies; 2) monitoring and analysis of policy and practices; and 3) developing policy options and recommendations that could increase access to these technologies for people with disabilities. The research protocol includes interviews with key stakeholders, analysis of relevant project materials and related policy and regulatory documents, and participation in relevant state and national meetings. The results of the policy research thrust may be essential to establish a body of credible evidence for influencing policy decisions at the state and Federal (U.S.) levels.

Some of the anticipated contextual variables influencing these policies include: location/geography (urban, suburban, inner city, rural & other variations); age; technological deployment, type of disability-related services needed and type of disability-related services available. Key and expert informants on technological application of universal design, disability policy, services, and advocacy were selected primarily for their expertise and experience in the implementation and diffusion of technology. Input from National Institute on Disability and Rehabilitation Research (NIDRR) funded Rehabilitation Engineering Research Centers (RERC) personnel, especially as it relates to the technical, legal, safety and efficacy issues that influence policy, process and regulatory change, is included in the emergent policy framework. Project research outcomes were discussed in a report assessing the status of policies and technologies affecting use of wireless and other communication technologies by people with disabilities.

POLICY CONTEXT

The Disability Community

Disability related issues affect a significant part of the U.S. population. An estimated 49.7 million men, women and children – almost 20 percent of the United States population – have a disability that to some degree impacts their everyday activities (Census, 2003). There are many types of disabilities, including sensory, physical, and cognitive, each of which may have varying degrees of severity. Whatever the circumstance or conditions, persons with disabilities are frequently limited to some degree in their participation in one or more normal life activities.

According to a report recently released by the National Organization of Disabilities (NOD) the “state of the union” is not the same for U.S. residents with disabilities as it is for U.S. residents without disabilities. As a community, persons with disabilities remain “pervasively disadvantaged” (NOD, 2002). The NOD report examined several aspects of disabled life in the United States, and presented pertinent demographic statistics based on 2000 and 2001 survey data:

• Only 32 percent of U.S. residents with disabilities of working age are employed
• People who have disabilities are roughly three times as likely to live in poverty (29 percent versus 10 percent), with annual household incomes below $15,000
• One out of five adults with disabilities has not graduated from high school, compared to less than one of ten adults without disabilities
• 35 percent of people with disabilities are not involved with their communities, compared to 21 percent of their non-disabled counterparts.

While 63 percent of people with disabilities say that life has improved in the past decade, many individuals are still in need of support and assistance. Could wireless based information and communication technologies be a key to helping persons with disabilities overcome the unique and diverse challenges they face? Only 25 percent of persons with disabilities own a computer compared to 66 percent for non-disabled adults. In addition, only 20 percent of people with disabilities have access to the Internet, compared to over 40 percent of U.S. adults who are classified as non-disabled (Kaye, 2000). While no comparable statistics catalog use of wireless technologies by people with disabilities, we can assume that the use is proportionate.

Key Stakeholders

There are many public and private organizations interested in promoting assistive technology (AT) and universal design (UD) concepts to the disabled community and the general population. These key stakeholders help to ensure appropriate information about the needs of the disabled community are disseminated into society, and help to ensure that civil rights and laws meant to support the disabled community are upheld. Many of these stakeholder groups are not-for-profit organizations that receive funding from private citizens or the Federal government. The resources they provide range from lists of products and services available for various disabilities, to information and education about the latest legislative actions that affect the disabled community. They are a critical component of the policy making process.

Legislative/Regulatory Policies

The facilitation of an environment that is inclusive of persons with disabilities has been a slow and complex process. Over the years, the Federal government has enacted legislation and developed policies affecting people with disabilities. Silverstein (2000) developed a valuable analytic framework, which classified these laws into five categories:

• Civil Rights Statutes – non-expiring laws that prohibit covered entities (such as state or local governments, and businesses) from discriminating against individuals on the basis of, or by reason of, disability. Examples include: The Americans with Disabilities Act (ADA), which prohibits discrimination on the basis of disability in employment, public services (including transportation), public accommodations and telecommunications; and Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination by recipients of Federal aid, such as hospitals, universities, and public schools.
• Entitlement Programs – guarantee eligible individuals a specified level of benefits (i.e., open-ended) or provide a state or other entity with a fixed allotment of funds over a specified period of time (close-ended). As an example of a closed ended program, Title XXI of the Social Security Act (otherwise known as the State Children’s Health Insurance Program (SCHIP)), guarantees $40 billion to states until 2007 to provide health insurance for low-income children who do not qualify for Medicaid including children with disabilities.
• Discretionary Programs – formula-based and competitive grants that provide supplementary Federal financial assistance to support specified activities carried out by other entities. An example of a formula grant program to state and local agencies that targets the needs of individuals with disabilities is Part B of Title VII of the Rehabilitation Act of 1973, which assists states in providing, expanding, and improving the provision of independent living services. The rehabilitation research funded by NIDRR was established under Title II of the Rehabilitation Act of 1973 and is an example of a discretionary program that offers competitive grants.
• Regulatory Statutes – provide minimum protections for a class of persons (including, but not limited to, persons with disabilities). Examples include: the National Voter Registration Act of 1993, which requires states to provide enhanced voter registration services at locations where driver’s licenses, public assistance, and state disability-related services are provided; and Section 225 of the Telecommunications Act of 1996, which requires that telecommunications equipment and services be accessible to persons with disabilities if readily available.
• Miscellaneous Provisions – provides funding for various programs through appropriations, tax legislation and loans. For instance, the “Disabled Access Tax Credit” is a miscellaneous provision that provides tax credits to small businesses for expenses incurred in becoming compliant with the Americans with Disabilities Act.

Key regulations targeted at addressing the concerns and needs of people with disabilities in terms of access are the Architectural Barriers Act, Section 508 of the Rehabilitation Act, the Assistive Technology Act, and Section 255 of the Telecommunications Act of 1996. One of the first major efforts toward accessibility regulation concerning physical access barriers is generally considered to be the Architectural Barriers Act of 1968 (P.L. 90-480) (U.S. Access Board, 2002). Adopted by Congress in 1968, it mandated the removal and avoidance of a variety of physical barriers to access in the design and construction of Federally funded buildings and facilities. Similar legislation has been ratified to eliminate analogous barriers to the access of wireless and other information and communications technologies. Section 508 of the Rehabilitation Act of 1973 (P.L. 94-541), as amended, ensures that electronic and information technology developed, procured, maintained, and used by the Federal Government is open and accessible for people with disabilities. However, this law applies only to the public sector. Section 255 of the Telecommunications Act of 1996, a comprehensive law which overhauled regulation of the telecommunications industry, requires telecommunications products and services to be accessible to people with disabilities. According to the Access Board, "readily achievable," means easily accomplishable, without much difficulty or expense.

As focal areas for improving the quality of life for people with disabilities, education, employment and community integration represent significant areas of recent policy activity. Congress is scheduled to reauthorize the Individuals with Disabilities Education Act (IDEA). As part of the reauthorization process, groups and committees are studying the current law and the manner in which it is being implemented. The President’s Commission on Excellence in Special Education (PCESE) has been holding hearings across the country since January 2002. PCESE’s final report was delivered to the President on July 1, 2002, per Executive Order 13227. The Commission’s report, A New Era: Revitalizing Special Education for Children and Their Families provided findings and gave major recommendations to consider for reauthorization of IDEA.

Recent U.S. Supreme Court decisions in employment-related cases continue to redefine and clarify the American with Disabilities Act (ADA). The high court ruled in the Toyota Motor Manufacturing, Kentucky, Inc. v. Williams that to qualify as disabled, a person must have substantial limitations on abilities that are “central to daily life,” and not only to life in the workplace. The decision in the Board of Trustees of the University of Alabama v. Garrett stripped the right of state workers to sue their employers for monetary damages for violations of Title I of ADA. In both of these cases, the Court has tended to narrow the ADA’s protections and coverage. At an annual meeting of the Corporate Counsel Institute at Georgetown University Law Center, Justice Sandra Day O’Connor observed that the Supreme Court “has been obliged to wrestle with a heavy load of disability rights cases because the 1990 Act was drafted too hastily by Congress” (Lane, 2002).

IDENTIFICATION OF CRITICAL POLICY ISSUES

As noted above an initial set of disability, wireless and communication technologies related policy issues was identified through research of not-for-profit agencies, government resources, and policy journals (GCATT, 2002). The first iteration examined two sub-policy arenas: disability policy issues, and telecommunications/wireless policy issues. Disability policy issues included: Access to Information, Community Living, Employment Opportunities, Expertise & Awareness, Health Care Coverage, and general Disability Policy concerns. Associated telecommunications/wireless policy issues included: Spectrum Allocation, Location Technology, Digital Divide, Device Incompatibility, Consumer Utility, Inter-Carrier Text Messaging / Universal Design. These were compiled into a two issue matrices (below). Subsequently these were collapsed into a set of key policy issues generally impacting the use of wireless and information and communications technologies by people with disabilities.

Initial Disability Policy Issue Assessment

Table A presents six issues that are of general concern to both the field of disability policy as well as wireless telecommunication and information technology deployment. These include:

• Technology Access
• Independent and Community Living
• Employment Opportunities
• Expertise & Awareness
• Health Care Coverage
• Disability Policy Arena

Access to Information

In today’s society, information is the principal component of our economic and social infrastructure. Wireless technologies, ranging from the computer to the GPS (global positioning satellite) receiver, from the wireless personal digital assistant (PDA) to the digital subscriber loop (DSL) line, have become a key medium for the transmission, storage, and manipulation of information. Ready access to information technology has therefore become a fundamental source of opportunity from education and employment to the attainment of a higher standard of living. The first piece of accessibility-related legislation adopted by Congress was the Architectural Barriers Act of 1968 (P.L. 90-480). The Act also “paved the way for creating and expanding parallel requirements to electronic and information technology in the information environment of today.” (NCD, 2001b) This evolution and progression has yielded the concept of “meaningful access”, or access that allows people with disabilities to fully participate in all aspects of community life. As outlined by the ADA, access can be defined as the “right to fully participate in enjoyment of whatever opportunities, benefits, programs, or services an organization covered by the law offers.” (NCD, 2001b) Under these criteria, access to information and to technology generating, transmitting, and storing has become a civil rights issue for many people with disabilities throughout the United States and the world.

Independent and Community Living

A physical community offers residents the benefits of pooled resources, support and a general camaraderie. Because disabled persons are often limited in mobility or communication capabilities, they can be limited in their interaction with the other people in their immediate vicinity. According to recent data, nearly one-third of persons with disabilities report that they do not interact with the other people or take advantage of available resources in their community. (NCD, 2001a) In addition, persons with disabilities are more likely to experience feelings of isolation within their communities than their non-disabled neighbors. Increased engagement by disabled persons could be enhanced by concerted efforts from Federal, state and local governments, as well as the private sector, to mitigate the barriers that disabled persons face in civic participation. The attributes of community living offer potentially tremendous medical and social benefits to persons with disabilities. U.S. residents with disabilities should therefore have full access to community-based care, quality mental health services, access to the political process, and access to ADA-exempt organizations such as religious organizations and clubs.

Employment Opportunities

The prevalence of high levels of under- and unemployment among U.S. residents with disabilities (68 percent) (Census, 2001) is economically inefficient and socially disadvantageous in light of recent disability policy, especially considering that skilled workers in many specialties remain in short supply. (DOL, 2003) The fact that computerization has both reduced the physical demands associated with many jobs and placed a premium on computer and related skills, facilitates a higher participation of disabled persons in the American workforce. Too often, even when people with disabilities find jobs, they are low-level, low-paying jobs. It is uncertain whether those disabled persons currently relegated to under-utilization and unemployment would be capable to enter and remain efficient members of the workforce if the necessary AT were accessible and usable.

In an era when computers and other forms of electronic and information technology are utilized in an increasing proportion in all businesses and fields, even in traditional manual-labor occupations such as manufacturing or agriculture, an investment in AT could potentially result in an increased opportunity and higher level of employment among people with disabilities. Indeed, employment numbers should be increasing, if for no other reason than that there are new ways for people to be employed. The deaf and hard of hearing use wireless “instant messaging” to have real-time conversations; the blind and people who are visually impaired use voice-synthesis technology to write and read documents and website information; people with limited movement ability in a traditional office have new ways to work from home. The National Rehabilitation Association strongly supports the principle that employment is integral to both health and wellness. Therefore, return-to-work would be a part of return–to-health for persons with disabilities. (Stewart, 2002) It follows that enfranchising this group of U.S. citizens would improve the health and wellness of society as well.

Expertise & Awareness

Gaining expertise in AT is akin to “swimming upstream,” given the rapid pace at which technology itself is changing. While increasingly usable, products built upon wireless technologies still are not as accessible as they could be. Individuals with disabilities find themselves in need of AT to remain autonomous and productive, yet access to expertise to assist in obtaining such technology is limited. While modest investments have been made in increasing the pool of individuals with AT knowledge and skills, there continues to be a significant shortage of available personnel with expertise in the field of AT. AT expertise needs to be cultivated and expanded in pre-service preparation programs, consumer empowerment activities, and other training venues. In addition to expertise, aggressive awareness initiatives are needed to educate the public and potential users about the existence and benefit of the AT available today. Recent reports continue to illustrate that consumers with disabilities are not aware of current assistive technologies that could address their functional or cognitive disabilities. (NCD, 2000) These studies also suggest that disabled persons tend to rely on personal interactions with families, friends, and service providers to obtain information about AT and services.

Health Care Coverage

Because the costs associated with purchasing, operating and maintaining assistive and facilitative technologies are very high, often the only opportunity to obtain such a device is through private insurance, Medicaid or Medicare assistance. Due to the disproportionate number of disabled people that are socio-economically disadvantaged, disabled persons must often rely on the latter two forms of medical assistance for acquiring AT. Because of their limited employment and reduced discretionary income, people with disabilities are more than twice as likely to delay needed health care because they cannot afford it. (NOD, 2001a) “The current definitions of durable medical care, medical equipment, and medical necessity provided by Medicaid and Medicare standards were enacted in the 1960s, when medical care was viewed primarily as curative and palliative, with little or no consideration given to increasing an individual’s functional status.” (NCD, 2000) Medicare coverage of AT reflects the narrow care bias that existed when the program was established in 1965. AT that does not meet narrow definitions of durable medical equipment or prosthesis are generally considered to be a “comfort” or “convenience” item. Technologies or devices falling outside these classifications are not covered, even when they are connected to the health or safety needs of the individual. As the largest payer for durable medical equipment, Medicare’s standards are commonly followed for coverage of AT in private health insurance. In addition, the Medicaid program is the primary financing mechanism for health and long-term services for many people with disabilities. Because of these antiquated limitations of what can and cannot be covered under Medicare, Medicaid and private insurance, financial support for AT is severely limited. (NCD, 2000)

Disability Policy Arena

The policy field addressing issues of disabilities is, itself, a convoluted arena of conflicting definitions, eligibility criteria, philosophical models, and requirements among various private and public entities. The goal of improving access to AT and wireless technology is a moving target. For example, just as inroads were made in ensuring AT coverage in health care plans, the health care industry underwent a fundamental change from fee-for-service to managed care in the early 1990s, and work began anew to ensure access to AT in managed care plans. Even when Federal policy is consistent, the vast majority of Federal programs are implemented at the state level with a corresponding myriad of inconsistencies and lack of coordination among various state agencies. As a result, AT access barriers continue to be created and removed at the state level, even when Federal policy is unchanged. Because disabilities transcend all gender, ethnic and age boundaries, the equally diverse Federal, state and local policies designed to assist disabled people only add to the confusion and frustration for people with disabilities, and associated advocacy organizations.

Initial Telecommunications/Wireless Policy Issue Assessment

Table B presents six current issues that are associated through the interrelation between new wireless and telecommunications technologies and the capability for disabled persons to lead a more connected and accessible lifestyle. These include:

• Spectrum Allocation
• Location Technology
• Digital/Disability Divide
• Device Incompatibility
• Consumer Utility
• Inter-Carrier Text Messaging / Universal Design

These issues, as were those in the preceding section, were derived through research involving industry, not-for-profit and government sources for information pertaining to current initiatives and emerging trends in areas that fall within the scope of the research project. Each constitutes a significant issue that currently exists at the intersection of wireless and telecommunications technologies and access/usability on behalf of those users who are disabled.

Spectrum Allocation

Radio spectrum is the portion of the electromagnetic radiation spectrum operating between the frequency limits of 9 kilohertz and 300 gigahertz. In the United States, the Federal Communications Commission (FCC) is responsible for administering spectrum for non-Federal government usage. The regulatory responsibility for Federal government utilization of the spectrum falls to the National Telecommunications and Information Administration (NTIA) within the U.S. Department of Commerce (Commerce). At issue in this analysis are the regulatory practices set forth by the FCC on the management of spectrum for third-generation wireless services.

If the next generation of the information superhighway is the wireless Internet, then radio spectrum is the concrete that will allow the construction of such a system. “Third generation”, or 3G wireless technology, provides access to a wide range of telecommunication services supported by fixed and mobile telecommunication networks. 3G (and subsequent advanced) services promise a more connected, capable and efficient lifestyle for all potential users. For those individuals who are disabled, the value of 3G technology goes beyond the mere novelty of such capabilities to a technology that supports a better standard of living.

For example, 3G phones under development would help people with hearing impairments lead more independent lives. Hearing-impaired users will be able to call up news, weather and sports information in sign language from a video server via 3G phones, give commands to their phones in sign language, and access real-time interpretation services to aid them in communicating with hearing people. (Perera, 2001)
One of the FCC’s functions is to set the rules for spectrum sharing (or non-sharing) through allocation, creating interference parameters and then acting as the arbitrator. Potential providers of 3G services have been lobbying for 120MHz of the current spectrum to be re-assigned for the expanded provision of 3G services. In the past, the allocation of specific services into their own dedicated pockets of spectrum has fostered a special interest mentality toward the FCC’s regulatory practices. The Commission often is faced with mediating cases of spectrum interference – in other words, contemplating whether certain spectrum interference gains outweigh other interference costs. The spectrum management objective of the FCC strives to create incentives for the efficient utilization of this valuable resource at every given point in time by established users and technologies as well as new entrants and nascent technologies.

3.0 The term “digital divide” refers to a gap between those who have access and can effectively use new information and communication tools, such as the Internet, and those who do not. While a consensus does not exist on the nature of the divide (and whether the divide is growing or narrowing), researchers are nearly unanimous in acknowledging that some sort of difference in access exists at this point in time. National funding to bridge the digital divide reached an all-time high in 2001. The investments from industry and government collaboration created jobs, expanded educational opportunities and even provided state-of-the-art health care to people far away from the nearest medical services. The productivity and economic growth during this period has been well documented. The Bush FY03 budget eliminated over $100 million in public investments previously available for community technology grants and information technology training programs that offer real payoffs to rural communities, the working poor, minorities, children and persons with disabilities. Still, the Administration remains focused on closing the “attainment gap” and The President is seeking billions of dollars for educational reform. Through the research and information dissemination efforts of various organizations, an outreach program could facilitate the inclusion of disabled persons into the population that is included on the disadvantages side of the digital divide. The conventional concept of the digital divide includes addressing access and use issues among socially, economically and geographically disadvantaged users. From the perspective of the disability community, access and use barriers are also relevant to those individuals with disabilities. The digital divide movement is only now beginning to recognize this population.
Digital/Disability Divide

Location Technology

Location technology provides the ability to determine a wireless telecommunications user’s location while the device is in operation. There are various processes to determine the location of a mobile device. One process is the “cell of origin” technique. In this procedure, the mobile network base station cell area is used as the location of the mobile handset. The positioning accuracy achieved depends upon the network cell size, which, if outside of urban areas, can be large. Perhaps more accurate than the “cell of origin” technique, the “time of arrival” process determines the mobile handset position by measuring the time of arrival of a handset signal to at least three network base stations, which are synchronized to compute the coordinates of a user’s location.

The ability to assess location – either from the user’s standpoint or from an external source – has tremendous value to both the disabled and non-disabled population. This technology is most closely associated with the “e911” initiative to provide a wireless telephone user’s location information. This location capability is often necessary to coordinate emergency services when the user is unable to communicate. Location technology also has potential for location specific advertising. Such advertising can notify a user when they are in a close proximity to a favorite restaurant or store. Location technology also has the potential to increase public safety by, for example, notifying a user about their proximity to a police station.

The e911 capability gives accurate and dependable location information in times of emergency regardless of a user’s inability or disability to effectively communicate. In addition, the user could voluntarily “opt-in” to receive location notifications through a telecommunications device that would be germane to a user’s disability. For example, a user could arrange to be notified when they are within a certain proximity to a dialysis clinic or even receive information about the accessibility of restaurants or stores within a certain radius to a user’s location. The location technology could be invaluable in the monitoring of those patients who wander off, or who have cognitive disabilities and may become disoriented and lost.

Consumer advocates worry that the new technology will create a barrage of cell-phone junk mail and, more seriously, jeopardize phone customers’ privacy. Because the proposed location technology within telecommunications devices would emit a signal revealing a user’s location at any given moment, there is potential for that information to be used as a violation of a person’s privacy and security. For example, if wireless service carriers track users' locations at all times, detailed records of a customer’s daily movements could be created. Those files could be subpoenaed and held against the user in a divorce or other legal action. This raises Fifth Amendment issues.

Disability Divide

The expression ‘disability divide’ draws upon the term ‘digital divide’ refers to a gap between those who have access to, and can effectively use, new information and communication tools, such as the Internet, and those who do not have such access, specifically in regard to people with disabilities. While a consensus does not exist on the extent of the divide (and whether the divide is growing or narrowing), researchers are nearly unanimous in acknowledging that some sort of divide exists at this point in time. The term, “disability divide,” a variant of digital divide, has recently emerged into the mainstream as it relates to the disabled community. This term is meant to refocus awareness of how the digital divide (generally thought of as the opportunity gap between the wealthy who have access to advanced technologies and the poor who do not) affects people with disabilities specifically, and to address the gap that remains between abled and disabled people despite advances in assistive technologies and more widespread awareness of implementing universal design. While creating web sites and technology that is accessible by all, it is equally important to improve beyond accessibility standard minimums. While building ramps to ensure access to a building addresses accessibility, building wheelchairs that can climb stairs pushes accessibility standards even farther.

“For many people with disabilities some new technologies are as much or more a barrier to than a source of access and inclusion. The cellular telephone is a great boon to many, but for people who use hearing aids, problems of incompatibility have made cell phones largely inaccessible and unusable. The graphical user interface has vastly enhanced access to high-speed data and pictures, but if Web sites are not designed with persons who use speech access in mind, these ubiquitous technologies become impenetrable walls checking access to the wealth of information and opportunity the Web conveys.” (NCD, 2002)

Despite the substantial growth of the Internet since the early 1990s, some citizens still do not have access to basic information technology (IT) tools, hardware, software, or the Internet itself. Access is an issue that affects people at home, at school and in the community at large. The disabled community, including the visually impaired, the homebound, and millions of people with other disabilities, often find themselves lacking access to basic Internet tools because of the limited investments in AT development, marketing, and dissemination.

National funding to bridge the digital divide reached an all-time high in 2001. Thanks in large part to industry and government collaboration, there was a substantial increase in investments during the last six years that enabled many communities to embrace digital technologies. The impact of this increased investment to remedy the digital divide produced new employment opportunities, expanded educational opportunities and even provided state-of-the-art health care to people far away from the nearest medical services.

This “disability divide” is a significant issue; in 1998, the Current Population Survey data showed that Americans with disabilities were “less than half as likely as their non-disabled counterparts to have access to a computer at home. The gap in Internet access is even more striking: almost three times as many people without disabilities have the ability to connect to the Internet at home as those with disabilities.” (Kaye, 2000) The suggestion that people with disabilities have the most to gain from access to technology (social, economic, and personal gains) illustrates the significance of this divide.

Device Incompatibility

Device incompatibility refers to the inefficient operation (or inoperability) of one or more electronic devices due to interference in operating mechanisms or media. For the purpose of this analysis, device incompatibility encompasses those electronic devices that are utilized by disabled persons as well as the medical devices employed by such persons. Inadequately shielded medical devices may be incompatible with many radio frequency sources including televisions, electronic power lines, pagers, AM, FM, CB, and amateur radios, police, fire, ambulance and paramedic radios, wireless personal computers and modems, wireless, cordless, and landline phones. The medical devices that many disabled persons depend on to achieve an acceptable standard of living could be rendered ineffective through interference with the frequency emitting devices listed above. The ineffectiveness or sub-optimal level of performance of medical devices utilized by this portion of the population could pose a serious or even fatal risk to a disabled person.

Wireless telecommunications has the potential to provide improved health care at lower cost to patients. Wireless telecommunications devices can offer health care administrators a method for managing their entire EMC environment. In that way, hospitals can experience the benefits that wireless technologies, like wireless phones, bring to health care and patient management. Studies have shown that hospitals that install compatible wireless telecommunications systems have demonstrated a significant improvement in the quality and efficiency of healthcare.
The digital electronics revolution brings many benefits to consumers, including advanced wireless telecommunications. However, the proliferation of digital technologies has also generated some interference and "growing pains" with devices designed before digital technologies became ubiquitous. Thus, many of these older devices do not include sufficient immunity to newer technologies. Of particular concern are the millions of people who rely on hearing aids to augment poor sound perception. [15] Some hearing aid wearers may experience interference (typically a "buzz") when in a close proximity to certain wireless telecommunications devices that are in use. Because information relating to device compatibility does not currently exist, it is the individual’s responsibility to determine the compatibility of hearing aid devices and the various telecommunications technologies.

Consumer Utility

This issue is concerned with the barriers created by cost and awareness of technology that persons with disabilities may have in obtaining or effectively utilizing wireless technologies. In differentiating itself from the digital divide concern, consumer utility examines the cases where the technology exists, but is not being efficiently utilized due to an array of financial and awareness issues. Even though valuable wireless telecommunications technologies are available to disabled individuals, there remain issues concerning the ability to financially afford such technology. In addition, some members of the disabled population may not even be aware of the potential value of a particular technology or product, or how to utilize a product or technology in order to produce maximum usage value.

To the portion of the population that is both economically challenged and disabled, the lack of access to insurance coverage is an overwhelming barrier to assistive telecommunications technologies. For this population, access to AT may be largely limited to health insurance providers, however legislation requiring AT be covered by insurance plans is lacking. Although the enactment of the ADA marked significant progress toward providing equal opportunity to employment and services for persons with disabilities, it did not provide similar opportunity for access to health insurance. For persons with disabilities, concerns about access to adequate and affordable health insurance drive decisions about many aspects of life. These decisions in turn are correlated to other choices on occupation, employment and living arrangements.

Inter-Carrier Text Messaging as a Component of Universal Design

“Universal design is the design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.” [16] As a component of universal design, inter-carrier text messaging is the ability to compose and deliver text messages between carriers and devices regardless of network, interface or device. Text messaging has long provided a medium for communication-impaired people to effectively communicate. Those individuals with speech disabilities can input a message via a keyboard apparatus into a wireless telecommunications device and send the message to another machine that is capable of receiving text messages. To date, text messaging has failed to catch on as a mainstream form of communication in the U.S. Until spring of 2002, text messaging was only available through the same carrier. Despite the recent advances in text messaging technology, and better inter-carrier compatibility, the feature is still widely underused among all users in the United States Users wishing to communicate via text messaging are required to have compatible devices and interfaces; this restriction prohibits communication between users who subscribe to different carriers and who used different devices. These obstructions can and likely will be eliminated if the demand for a flexible text messaging infrastructure increases among all users, at which point a natural push for inter carrier compatibility would occur.

Revised Policy Issue Assessment

Following publication of the first version of the policy assessment, comments and suggestions received allowed the development of a subsequent list of ten key policy issues. While many issues touching on technology and accessibility are of concern to a number of disability-related interests, the following list details ten policy issues focusing on wireless and information technologies or application of technologies that impact the quality of life for people with disabilities. These include:

• Affordability of assistive technology (AT) products
• Definition of telecommunication/information services
• Disability divide/access/awareness
• E-911 (wireless) call accuracy
• Inter-agency coordination
• New Freedom Initiative
• Re-prioritizing the nation’s disability and rehabilitation research agenda
• Spectrum allocation/availability
• Universal design and product development
• Wireless device (in)compatibility

Affordability of assistive technology products

AT products are frequently not covered by health insurance plans (private or public), making affordability a key issue. Legislation that regulates insurance coverage of these products either does not exist or is very difficult to find. People with disabilities often need expensive equipment, such as specialized wheelchairs or assistive devices; the lack of financial options available to the disabled community creates barriers to meeting basic needs such community participation, employment, and economic independence met.

Definition of telecommunication/information services

While Section 255 of the Federal Communications Act defines “telecommunication services” as services that facilitate and carry voice communication; e-mail and data transmission capabilities are technically not covered under this section. The FCC is seeking to broaden the definition of “telecommunication services” to include these other applications.

Disability “Divide”

Access to telecommunications technologies does not appear to be equal between people with and without disabilities partially as a result of cost of services and lack of awareness of services availability. A National Council on Disability (NCD) Report [2003] notes that many people with disabilities see advances in technology as barriers rather than vessels of easier access. Cell phones and PDA’s facilitate increased communication unless those people are deaf or require voice-activated software to utilize information technologies.

911 (wireless) call accuracy

E-call centers do not currently have the necessary infrastructure to determine the exact location of a wireless call. The FCC has required that wireless carriers provide technology that can pinpoint callers’ locations in emergency situations. Emergency dispatchers receiving e-911 calls placed from cellular phones are unable in many places to pinpoint the location of the caller. Limited financial resources, lax enforcement of regulation, lack of access to proper technologies and regulatory considerations all contribute to this failure.

Federal inter-agency coordination

Government agencies responsible for the accessible dissemination and regulation of disability-related legislation may be generating redundant efforts toward the implementation of key disability related legislation. The Secretaries of Education, Health and Human Services, Labor, and Commissioner of Social Security established the Interagency Working Group on Assistive Technology Mobility Devices (Working Group) to improve the coordination of the Federal programs that help provide individuals with disabilities AT mobility devices.

Federal New Freedom Initiative

Among the Initiative's goals are increased access to assistive and universally designed technologies; expansion of educational opportunities; integration of Americans with disabilities into the workforce; and promotion of full access to community life. An early result of this is the requirement that Federal agencies work together to build a single website addressing the issues and needs of people with disabilities. The goal of the website is to provide individuals with access to government information and resources related to disability issues and the President’s New Freedom Initiative from DisabilityInfo (http://www.disabilityinfo.gov/).

Re-prioritizing the nation’s disability and rehabilitation research agenda

The U.S. Department of Education announced a new web site developed by the Interagency Committee on Disability Research (ICDR), which will be used to gather information about research needs for Americans with disabilities. The ICDR was mandated “to promote coordination and cooperation among Federal departments and agencies conducting rehabilitation research programs.”

Spectrum allocation/availability

Proposed changes to spectrum allocation policies allowing broader deployment of 3G technologies could support new assistive technologies. The telecommunications industry could see an improvement in the service coverage that is available to users, an enhancement of device reliability and quality, and an improvement in overall customer satisfaction with a given technology. A revamped process for spectrum allocation could set aside spectrum for uses that while not necessarily the most economical, could offer other social benefits.

Universal design for products

Lack of communication between product designers and potential consumers hamper the development universal design (UD) concepts. 49.7 million citizens have some degree of disability and may be underserved by modern technologies because of product design. Despite the size of this potential product market, manufacturers may not be designing suitable products to accommodate the needs of the disabled community, either through UD or AT (AT). Increasing awareness of AT/UD parameters are critical to the development of new products.

Wireless device (in)compatibility

Wireless devices, which tend to be developed to meet specific requirements may interfere with each other, resulting in inefficient product functioning. For example, motorized wheelchairs may receive interference from wireless devices (phones, PDAs), and hearing aids are not compatible with some wireless phones, which cause one or the other of the devices to function incorrectly. Digital phones can cause hearing-aids to buzz uncomfortably. As part of the revisions to Part 22 of FCC rules, the FCC plans to monitor wireless progress on this issue by requiring progress reports on their research and development in years three and four of the five-year plan (FCC, 2001).

FACTORS ASSESSMENT

The policy issues examined in the preceding sections represent significant focal areas from both a disability and wireless telecommunications perspective that impact access to technology. In analyzing the intersection of disability policy and wireless technologies three underlying barriers to access/use appear to be relevant to this nascent environment of disability and technology collaboration, i.e., awareness and proficiency factors, economic barriers, and incompatible technologies.

Barriers to Access/Use

Awareness/Proficiencies

A primary concern associated with the deployment and use of wireless and other telecommunications technologies by people with disabilities is a lack of awareness that a given technology exists, or that it could be of benefit. The purpose and potential utility of a technology must be known in order to associate value with the product. This component of awareness and a user’s proficiency with a technology constitutes the first barrier on behalf of disability access to assistive telecommunications technologies. Because the environment of wireless related technologies is in a perpetual state of development, the sheer volume of new products and technologies is staggering. In addition to lacking a reliable method of communicating advances in AT/ UD, assessment of these new products is rarely, if ever, completed with consideration of the specialized needs and requirements of disabled persons. As a result, the current and potential users of telecommunications technologies may be significantly uninformed as to the availability or utility of these devices.

At present, current or potential users of assistive telecommunications technologies must actively seek out appropriate information from researchers, manufacturers or policy makers. While factors such as socio-economic or geographic circumstances may contribute to lack of pertinent information available to prospective AT users, the single greatest barrier to efficient information dissemination is the insufficient resources currently invested in formulating effective awareness campaigns. The responsible parties to promote and inform the public on assistive technologies – namely, government, industry and not-for-profit organizations – lack the appropriate resources, incentive, organization, or in some cases, simply the awareness that such efforts are necessary.

Another component of awareness is that users lack familiarity with the technologies. In this capacity, lack of familiarity is manifested through two different types of user attitudes. Some users, frequently those who are older or economically disadvantaged, could harbor feelings of skepticism about the benefits or effectiveness of wireless telecommunications technologies – perhaps as a result of previous experiences of culturally ingrained attitudes. In addition, some persons with disabilities may use an assistive telecommunications device without a complete understanding of a device’s capabilities or operating functions. Alternatively, the design of the device (i.e. extensive system menu prompts) may be for all intents inaccessible for certain users.

Economic Barriers

The most complex (and useful) wireless devices with the potential for dramatically improving the standard of living for a disabled person tend to be prohibitively expensive to a portion of the population already more likely to be unemployed or receive government assistance. Because the potential value of such technologies has not been fully realized, these devices are often not covered under private health insurance plans, employer-based health benefits, or the two primary public health insurance programs for persons with disabilities – Medicaid and Medicare. Some states have initiated low-interest loan programs and sales tax exemptions to assist persons with disabilities with the purchase of AT. However, because the utility of assistive telecommunications technologies has not been fully appreciated, such devices are often not included in such state programs. The introduction of wireless assistive technologies, requiring additional hardware and software capabilities, further complicates the expensive/utility aspects of these technology purchases and must be addressed.

Technology Incompatibilities

Technological inconsistencies, or incompatibilities, across products of different design, manufacturer, or purpose can create barriers to the efficient and effective operation of devices by potential users. Disabled people, who rely on such devices, are especially susceptible to harm if such inconsistencies render a medical or communication device ineffective. As some telecommunications and medical devices operate in overlapping or adjacent frequency spectrum ranges, there does exist a possibility for malfunction and potential harm. Quite often medical centers post signs prohibiting the use of certain devices within certain proximity to medical equipment, but for some disabled persons the use of assistive telecommunications devices are necessary to function in daily life. Designers and manufactures of incompatible devices are not effectively collaborating to ensure that such vital devices are reliable and efficient in all circumstances and situations.

Opportunities

The key policy issues presented above represent opportunities for policy strategies and/or technological design approaches to improve access on behalf of those people who are disabled. Closer examination of the issue confluence of disability policy and wireless technologies reveals three principle areas of opportunity, policy/regulatory interventions, market mechanisms, and outreach/awareness prospects.

Proposed Policy/Regulatory Interventions

Policy and regulatory interventions on behalf of wireless telecommunications technologies (including assistive as well as general devices) can affect the success or failure of a product or methodology. Proposed policies and regulations in this field address many issues and take many forms, but consistent support can be found for two main initiatives across the diverse assistive telecommunications organizations, groups and supporters. Ideally these directives and others like them will not only encourage the development of new devices but also reinforce the importance of AT being flexible and useable by all people. If products and services are not useable, the extent of their accessibility becomes moot.

The first initiative concerns extension of Section 508 of the Rehabilitation Act of 1973, as amended, to all public institutions. Currently, Section 508 for information technology accessibility apply only to Federal agencies. Recipients of Federal funds and the private sector are not responsible to the regulations as set forth by Section 508. States that receive Federal funds under the Assistive Technology Act of 1998 are required by that Act to provide proof of compliance with the requirements of Section 508. Currently all states and territories receive AT Act dollars and report some form of Section 508 assurance, however these compliance assurances provide few specific details about how compliance is being met. This lack of consistency and detail in state execution of Section 508 invokes several concerns:

• What state entities are subject to the requirements
• What accessibility standards will be used to determine product compliance
• What procedures will be used to review products prior to purchase
• Who is responsible for oversight and compliance
• What recourse is available for enforcement

The opportunities presented by universal applicability of Section 508 would support the development and procurement of accessible information technology in all public entities, including state, county and local governments and schools.

The second initiative supports increased access to assistive and universally designed telecommunications technologies. The president’s New Freedom Initiative (Bush, 2001) emphasizes the development of assistive technologies by providing funding for the creation of more and better AT. The initiative also provides funding to expand educational opportunities for people with disabilities, and provides funding to increase the integration of people with disabilities into the work force by encouraging telecommuting and encouraging transportation solutions. Finally, the initiative also promotes better access to community life for people with disabilities through financing options for purchasing homes, and ensuring the accessibility of community organizations such as churches and civil society institutions. As a component of President Bush’s New Freedom Initiative (Bush, 2001), this intervention could provide support for the Rehabilitative Engineering Research Centers’ budgets for promoting new assistive telecommunications technologies. As technology and product “developers”, these Centers collaborate with various industry organizations to assist in bringing new technologies and products to market. Because assistive technologies are often too expensive for most users, this proposed policy and regulatory opportunity would provide support for low-interest loan programs for the purchase of assistive telecommunications products.

Market Mechanisms

Markets are recognized to be a critical driver in the development and deployment of innovations, technologies and new products. Assistive telecommunications technologies have long been thought of as a very specific product designed for a very small fraction of the population – namely, those persons who are disabled. Recent data suggests that the definition of “disabled” is not as exclusive as was previously thought. A person is considered to have a disability if he or she has difficulty in performing certain functions, or has difficulty in performing activities of daily living, or has difficulty with certain social roles. Any person who has difficulty with one or more of the above activities, depends on an assistive device for one of the above activities, or who depends on another caretaker for basic activities, is considered severely disabled. Millions of U.S. residents who had previously attributed their difficulty or inability to perform certain tasks to seemingly trivial physical deficiencies can now be considered as “disabled” to some degree under these definitions supported by the Census Bureau, and now account for a 20 percent share of the citizenry of this country. According to the most recent Census data, about 1 in 5 U.S. residents are considered somewhat disabled, with approximately 1 in 10 being considered severely disabled. (U.S. Census, 2003) These figures, coupled with the fact that the mean age of the American population is increasing (and along with age comes an increased chance for the onset of a disability), the total number of people in the United States with disabilities is expected to continue to increase.

Because a smaller percentage of people in previous years were considered to be disabled, there has been a deficiency in quality research that documents the market potential of assistive technologies. As a result, it has been difficult to convince designers and manufacturers on the economic viability of such products. Not only are there more potential disabled consumers than previously thought, but manufacturers must also realize that assistive technologies can also benefit the non-disabled public at large. Assistive telecommunications technologies facilitate a more efficient data transfer between users who would otherwise have difficulty utilizing conventional means of communication. Although not required by non-disabled users, such assistive telecommunications technologies could offer a more convenient or efficient alternative to existing technologies.

Outreach/Awareness

Because the inefficient dissemination of information regarding available assistive and wireless telecommunications technologies, products and methodologies continues to be a barrier to the effective delivery, usage and understanding of such aides, the outreach and awareness opportunity is vital to successful utilization. As noted above, the financial incentive to implementing an effective advertising campaign simply does not exist from the manufacturers’ point of view. Therefore, other means must be employed to deliver the relevant information to those who can benefit from such assistive technologies the most – disabled persons. There exist four primary mediums through which information can be effectively disseminated to unsuspecting and potential beneficiaries of assistive telecommunications technologies, products and methodologies: industry or not-for-profit organizations, conferences, government entities and user forums.

CONCLUSIONS

The concept of disability is changing in the United States. The perception of a disabled person as someone with an obvious physical or cognitive deficiency or impairment is changing into a broader, more inclusive label that applies to a much larger portion of the population. We as a society are currently at a very crucial point in the realization that access and usability is not as equitable as we had previously thought. A fundamental portion of access and usability is the ability to effectively transmit and receive information. As the landscape of access on behalf of disabled persons is quite broad, the purpose of the policy assessment has been to review those policies that are germane to persons with disabilities’ access to wireless telecommunications technologies. Further, as a component of universal design, nascent technologies should be designed to accommodate as many possible users and their special needs as possible. Recent developments such as audio or visual aides in crowded areas – vital to sensory impaired individuals – have facilitated a very effective method of information dissemination among the non-disabled as well.

Research to determine other potential benefits for both the disabled and non-disabled communities alike must be sustained to foster the idea that wireless and other telecommunications technologies are more than a specific product with a narrow market and financial burden for manufacturers. Previously, research concerning specific applications of the technologies, such as AT, focused on the costs associated with implementing and providing the services – provisions often mandated through legislative or regulatory policies. Future research concerning wireless technologies need to include the positive attributes of these devices for universal design and methodologies if 1) AT products are to find their way into the mainstream market, and 2) wireless technologies become more generally accessible to people with disabilities.
With the power of member industry, academic and other organizations, market mechanisms stirred as a result of changing attitudes with regards to assistive telecommunications technologies could make significant strides toward reducing the barriers to access and use discussed earlier in this analysis. With a larger potential market base, both AT and UD –centric wireless telecommunications technologies would enjoy the benefits associated with a competitive marketplace – thereby offering improved technologies at affordable prices. Marketing the capabilities and benefits of these telecommunications technologies has always presented problems for both producers and users alike. However, with the larger market base described above, innovative application and device developers would have incentive to initiate an effective advertising campaign. In addition, through the increased investment in product research and development, as well as the desire to have a unique product identity, the previous problems of technology incompatibility would be remedied.

Wireless technologies offer our society the means to lead a more independent, knowledgeable and convenient lifestyle, unfettered by physical locale, making information readily available regardless of location or time. For the portion of our population who suffer from some degree of disability, assistive telecommunications technologies are often more a necessity than a convenience. Wireless information devices can provide an avenue to achieving higher standards of living for persons with physical or cognitive disabilities. Basic design principles behind assistive technologies can prove useful to a much larger portion of the population than previously imagined. Larger markets for these technologies provide incentives to development of new products. Finally, a policy agenda placing an emphasis on expanded research and support initiatives to develop new applications of telecommunications technologies can result in increased opportunities for people with disabilities, and reduce barriers existing in day to day living.

NOTES

1. The research reported here is being conducted under the auspices of the Rehabilitation Engineering Research Center on Mobile Wireless Technologies for Persons with Disabilities (Wireless RERC), funded by the National Institute on Disability and Rehabilitation Research (NIDRR) of the U.S. Department of Education under grant number H133E010804. The opinions contained in this publication are those of the grantee and do not necessarily reflect those of the U.S. Department of Education. The authors wish to acknowledge the work of Lynzee Head, Andy McNeil and Lisa Griffin who were researchers on a previous draft of the project report.

2. U.S. Department of Commerce (2000)

3. National Council on Disability (2001b)

4. National Organization on Disability (2002)

5. NCD, 2001a

6. NOD, 2002

7. NCD, 2001a

8. NOD, 2002

9. NCD, 2002

10. NCD, 2000

11. Ibid.

12. Ibid

13. Ibid.

14. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-01-320A1.txt

15. On July 10, 2003, the FCC modified the exemption for wireless phones under the Hearing Aid Compatibility Act of 1988 to require that wireless phone manufacturers and wireless phone service providers make digital wireless phones accessible to individuals who use hearing aids.

The FCC ruling requires digital wireless phone manufacturers to make available to carriers within two years at least two HAC-compliant handsets with reduced RF emissions for each air interface (e.g., CDMA, TDMA, GSM) it offers and each carrier providing digital wireless services, except for nationwide (Tier I) wireless carriers, to make available to consumers within two years at least two HAC-compliant handset models with reduced RF emissions for each air interface it offers. [http://www.fcc.gov/cgb/consumerfacts/accessiblewireless.html]

16. Ron Mace, NC State University, The Center for Universal Design. 1997. [http://www.design.ncsu.edu/cud/univ_design/ud.htm]

REFERENCES

Bush, George, W. 2001. New Freedom Initiative, Executive Order. Washington D.C., The Whitehouse, [http://www.whitehouse.gov/news/freedominitiative/freedominitiative.pdf].

Federal Communications Commission (FCC). 2002. Section 68.4(a) of the Commission’s Rules Governing Hearing Aid-Compatible Telephones, Washington D.C., FCC. [http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-01-320A1.doc]

Georgia Centers for Advanced Telecommunications Technology (GCATT). 2002. Policy and Regulatory Assessment: Factors influencing Adoption of Wireless Technologies: Key Issues, Barriers and Opportunities for People with Disabilities. Atlanta, GA: Office of Policy and Programs, GCATT, and Wireless RERC. [http://www.wirelessrerc.gatech.edu/projects/research/r3_PAaug.html]

Georgia Centers for Advanced Telecommunications Technology (GCATT). 2000. DigitalGeorgia: A White Paper on Information and Communications Technology in Georgia. Prepared for the Office of the Governor. Atlanta, Georgia: Office of Policy and Programs, GCATT. [http://www.digitalgeorgia.org/]

Kaye, H.S. Computer and Internet Use Among People with Disabilities. 2002. Disability Statistics Report (13). Washington, DC: U.S. Department of Education, National Institute on Disability and Rehabilitation Research.

Lane, Charles. 2002. “O’Connor Criticizes Disabilities Law as Too Vague.” The Washington Post. March 15, 2002, Page A02.
National Council on Disability. 1994. Making Healthcare Reform Work for Americans with Disabilities. Washington D.C. [http://www.ncd.gov/newsroom/publications/pdf/town.pdf].

National Council on Disability. 2000. Federal Policy Barriers to Assistive Technology. Washington D.C. [http://www.ncd.gov/newsroom/publications/pdf/assisttechnology.pdf].

National Council on Disability. 2001a. Investing in Independence: Transition Recommendations for President George W. Bush. Washington D.C. [http://www.ncd.gov/newsroom/publications/pdf/bush.pdf]

National Council on Disability. 2001b. The Accessible Future. Washington D.C. [http://www.ncd.gov/newsroom/publications/pdf/accessiblefuture.pdf]

National Council on Disability. 2002. National disability Policy: A Progress Report December 2000-December 2001. Retrieved from http://www.ncd.gov December 18, 2002.

National Council on Disability. 2002a. Supreme Court Decisions Interpreting the Americans with Disabilities Act. [http://www.ncd.gov/newsroom/publications/pdf/supremecourt_ada.pdf].

National Council on Disability. 2003. National Disability Policy: A Progress Report December 2001-December 2002. Washington D.C.: National Council on Disability. [http://www.ncd.gov/newsroom/publications/progressreport_final.html].

National Institute on Disability and Rehabilitation Research (NIDRR). 1999. NIDRR’s Long Range Plan – Associate Disability Research, Section 2, Chapter 7. Washington D.C. [http://www.ncddr.org/new/announcements/nidrr_lrp/index.html].

National Organization on Disability. 2001a. Access to Health Insurance. [http://www.nod.org/]. Washington D.C.

National Organization on Disability. 2002. The State of the Union 2002 for Americans with Disabilities. Washington D.C. [http://www.nod.org/content.cfm?id=751].

Perera, Rick. 2001. Update: Researchers Developing 3G Phone for Deaf People. IDG.net. [http://www.idg.net/idgns/2001/05/09/UPDATE3GResearchersDeveloping.shtml]

Rehabilitation Engineering and Assistive Technology Society of North America (RESNA). 2002. Technical Assistance Project. [http://www.resna.org/taproject/policy/statepolicy/flash.html].

RESNA. 2002. Technical Assistance Project: Policy Information Pipeline – Emerging Initiatives – Section 508. [http://www.resna.org/taproject/policy/initiatives/508.html].

RESNA. 2001. Technical Assistance Project, Policy Information Pipeline: State Policy Flash. Retrieved from [http://www.resna.org/taproject/policy/statepolicy/flash.html].

Silverstein, Robert. 2000. “Emerging Disability Policy Framework: A Guidepost for Analyzing Public Policy.” 85 Iowa Law Review 1691.
Stewart, Thomas G. 2002. National Rehabilitation Association Issue Statements 2002. National Rehabilitation Association. [http://www.nationalrehab.org/website/govt/200207.html].

Technology-Related Assistance for Individuals with Disabilities Act (Tech Act). 1988. H.R. 4904. [http://thomas.loc.gov/].

U.S. Census Bureau (Census). 2001. Americans with Disabilities: 1997 - Table A. August-November 1997 Survey of Income and Program Participation. Washington D.C.: U.S. Department of Commerce. [http://www.census.gov/hhes/www/disable/sipp/disab97/ds97ta.html].

U.S. Census Bureau (Census). 1997. Census Brief CENBR/97-5. Washington D.C.: U.S. Department of Commerce. [http://www.census.gov/prod/3/97pubs/cenbr975.pdf]

U.S. Census Bureau (Census). 2003. Disability Status: 2000. Washington, D.C. : U.S. Department of Commerce. Issued March 2003, C2KBR-17. [http://www.census.gov/hhes/www/disability.html].

U.S. Department of Commerce (DOC). 2002. A Nation Online: How Americans Are Expanding Their Use of the Internet. Economics and Statistics Administration (ESA), and the National Telecommunications and Information Administration (NTIA). Washington. D.C. [http://www.ntia.doc.gov/ntiahome/dn/anationonline2.pdf]

U.S. DOC. 2000. “Part III: Internet access and computer use among people with disabilities.” Falling Through the Net: Toward Digital Inclusion. Washington, D.C.: USDOC, ESA and NTIA, [http://www.ntia.doc.gov/ntiahome/fttn00/Falling.htm].

U.S. Department of Justice (DOJ). 2000. Information Technology and People with Disabilities: The Current State of Federal Accessibility. [http://www.usdoj.gov/crt/508/report/content.htm]

U.S. Department of Labor (DOL). 2003. Office of Disability Employment Policy data. [http://www.dol.gov/odep/].

United States Access Board. 2002 Architectural Barriers Act of 1968. [http://www.access-board.gov/about/ABA.htm].

Workforce Investment Act (WIA). 1998. U.S. Department of Justice Section 508 Home Page. [http://www.usdoj.gov/crt/508