NCD retrospective on GUI (fwd)

From: David Andrews (dandrews@winternet.com)
Date: Fri Mar 29 1996 - 23:30:43 PST


Here is a report that may be of interest.
David Andrews

---------- Forwarded message ----------
Date: Fri, 29 Mar 1996 12:44:18 EST
From: Jamal Mazrui <74444.1076@COMPUSERVE.COM>
To: Multiple recipients of list EASI <EASI@SJUVM.STJOHNS.EDU>
Subject: NCD retrospective on GUI

GUIDANCE FROM THE GRAPHICAL USER INTERFACE (GUI) EXPERIENCE:

                         What GUI Teaches
About Technology Access

                  National Council on Disability
                          March 28, 1996

National Council on Disability

Guidance from the Graphical User Interface (GUI) Experience:
What GUI Teaches about Technology Access

Publication date: March 28, 1996

National Council on Disability
1331 F Street, NW, Suite 1050
Washington, DC 20004-1107

(202) 272-2004 Voice
(202) 272-2074 TT
(202) 272-2022 Fax

The views contained in the report do not necessarily represent
those of the Administration, as this document has not been
subjected to the A-19 Executive Branch review process.

NATIONAL COUNCIL ON DISABILITY
MEMBERS AND STAFF

Members

Marca Bristo, Chairperson
John A. Gannon, Vice Chairperson
Yerker Andersson, Ph.D.
Larry Brown, Jr.
John D. Kemp
Audrey McCrimon
Bonnie O'Day
Lilliam R. Pollo
Debra Robinson
Shirley W. Ryan
Michael B. Unhjem
Rae E. Unzicker
Hughey Walker
Kate P. Wolters
Ela Yazzie-King

Staff

Ethel D. Briggs, Executive Director
Speed Davis, Executive Assistant to the Chairperson
Billie Jean Hill, Program Specialist
Jamal Mazrui, Program Specialist
Mark S. Quigley, Public Affairs Specialist and Editor
Brenda Bratton, Executive Secretary
Stacey S. Brown, Staff Assistant
Janice Mack, Administrative Officer

TECH WATCH

Chairperson

Bonnie O'Day

Staff

Jamal Mazrui

Members

 Eric Bohlman
Judy Brewer
Debbie Cook
Roberta Cook
Norman Coombs
Tim Cranmer
Charlie Crawford
 June Kailes
 Debbie Kaplan
 Cindy King
 Paul Schroeder
Gregg Vanderheiden

ACKNOWLEDGMENT

     The National Council on Disability wishes to express its
sincere appreciation to
Bonnie O'Day and Jamal Mazrui for their leadership in technology
accessibility, and to Fred Pelka for his hard work and valuable
suggestions in preparing this report.

                         TABLE OF CONTENTS

Preface.......................................................vii
Introduction....................................................1
The GUI Crisis..................................................3
     What Is GUI?...............................................3
     What Is the Crisis?........................................3
     Why Microsoft?.............................................5
     Early Awareness of the Problem.............................6
     The Crisis Develops........................................7
     NCD's First Involvement...................................10
     Advocacy for Open Windows.................................12
     ADA.......................................................12
     Section 508...............................................13
     The Tech Act..............................................14
     NCD Efforts...............................................16
     Toward a Resolution ......................................18
     NCD: What Went Wrong, What Went Right....................20
Recommendations................................................23
Conclusion.....................................................29
Appendix: National Council on Disability: A Brief Description.31

                              PREFACE

     In August 1994, members and staff of the National Council on
Disability (NCD) began meeting with representatives of the
disability community and officials of Microsoft Corporation to
discuss access to Windows-based software for people with
disabilities, especially people with severe visual impairments.
     As part of its research agenda, NCD established Tech Watch,
a community-based, cross-disability consumer task force on
technology. The 11-member task force provides information to NCD
on issues relating to emerging legislation on technology and
helps monitor compliance with civil rights legislation, such as
Section 508 of the Rehabilitation Act of 1973, as amended.
     This report was commissioned by NCD on the advice of Tech
Watch. It is a retrospective analysis of the crisis for people
with visual disabilities that was caused by the widespread
adoption of the graphical user interface in information
technologies. Numerous interviews were conducted to trace the
history of the crisis and the response from the disability
community in general and NCD in particular. The report makes
recommendations to NCD on how such a crisis might be averted in
the future, so that people with disabilities will benefit as much
as others, from advances in technology.

                           INTRODUCTION

The blind community is at the highest risk right now of being
first liberated by computers in the eighties, and now enslaved in
the nineties. (Charles Crawford, Boston Globe, October 17, 1994.)

     In early January 1994, Henry Archin went for a job interview
at Wellfleet Communications in Billerica, Massachusetts. Archin,
totally blind since birth, was hoping for a position in the
company's telephone customer service department. The interview
went well, and Archin asked the Massachusetts Commission for the
Blind to evaluate what special equipment or software he might
need to work in Wellfleet's computer environment. That's when he
heard the bad news.
     Wellfleet uses Microsoft Windows, a computer program with a
graphical user interface (GUI). Office software that uses an
entirely text-based interface can be made relatively accessible
to a blind user through a screen reader program that converts
what is on the screen into braille or synthetic speech; however,
there is no equivalent program for Windows reliable enough to
enable Archin to do the job. A Wellfleet representative
expressed his regret, but Archin did not get the position.
     Charles Crawford, commissioner at the Massachusetts
Commission for the Blind, uses the folk tale of John Henry to
illustrate the situation of blind computer users in America
today. John Henry, it will be remembered, was "a steel drivin'
man" who raced a mechanical rail-driver in an attempt to save his
job. John Henry won the race, but lost his life. Steel driving
men passed into history, tossed out of their jobs by changing
technology.
     The crisis that graphical user interfacing poses to blind
computer users has been building for a long time. Ever since the
introduction of GUI (pronounced "gooey") into the software market
in the mid-1980s, software accessibility experts had warned of
the potential for lost jobs and careers as people who were blind
or visually impaired were confronted by a new technology that was
impossible for them to use. By 1994, with the imminent unveiling
of Microsoft's Windows 95, this nightmare seemed on the verge of
becoming reality, as
more and more offices contemplated the switch from the older,
disk operating systems (DOS) to Windows. "The reality," wrote
Crawford that year, "is as cold as the unemployment lines that
may soon become the home of thousands of people who are blind."
     This report was commissioned by the National Council on
Disability's (NCD) Technology Watch task force. Tech Watch was
established by NCD in January 1995 and consists of Council
members, software accessibility experts, and technology
accessibility advocates and consumers. The purpose of the report
is to trace the development of and community response to the GUI
crisis. How did this crisis happen? Could it have been
prevented or attended to earlier, before it began to compromise
the livelihoods of people with disabilities? What was the role
of NCD in resolving the crisis? What can NCD do to prevent
similar crises?
     The report also examines the effectiveness of current
legislation in dealing with this issue. In particular, advocates
turned to the Americans with Disabilities Act (ADA), Section 508
of the Rehabilitation Act, and the Technology Related Assistance
for Individuals with Disabilities Act in their efforts to
convince the software industry to incorporate access into their
products. How well did the language of these laws meet the needs
of the day? How well are the laws being enforced? And what can
NCD do to ensure that these laws and their enforcement better
serve the needs of Americans with disabilities?

THE GUI CRISIS

What Is GUI?
     A computer user interface is the place where machine and
human being communicate with each other. It is how we tell
computers what we want and how they present to us the information
we request. Today, the most common user interfaces involve a
keyboard, viewscreen, and, more and more often, a mouse.
     A graphical user interface is a computer-user interface that
uses graphical screen images as well as typed text, with icons on
the screen replacing many of the functions of the keyboard. For
example, in a typed text interface, the command to move data from
one file to another is typed into the computer as a line of code
meaning, "Send this letter from file A to file B." In GUI, a
user might send this command by placing the cursor on the letter
(represented by the image of an envelope), and moving it with a
mouse across the screen from file A (represented as a rectangle),
to file B (represented as another rectangle). Click the mouse,
and the transfer is complete. Many sighted people find GUI
easier to use, because they don't have to remember or to look up
special commands for each program function. Less time is spent
figuring out how to get the computer to do what you want it to
do.
     GUI can be used by people who are blind and visually
impaired, provided they have a reliable screen reader to
translate what's on the screen into braille or synthesized
speech. The development of screen readers for the older,
DOS-based systems is quite advanced, and a number of private
companies presently compete for the screen reader market.

What Is the Crisis?
     GUI offers a special challenge to designers of screen reader
programs. In text-based interfaces, almost everything on the
screen is a letter, a number, or punctuation, and is easily
discernable by the screen reading program. Furthermore, in these
earlier systems, the
information flow to and from the screen is relatively accessible
to the screen reader. In graphical user interfaces, however, the
screen can contain many symbols or icons, which are much more of
a problem for screen readers to decipher. In addition, the
information that is sent to and from the screen is more difficult
for screen readers to interpret. And of course, GUI is at heart
a presentation system designed with sighted people in mind.
Successive menus, pull-down windows, icons, screen buttons,
bombs, palettes-all were introduced to provide greater ease for
sighted users.
     Gregg Vanderheiden, director of the Trace Research and
Development Center at the University of Wisconsin-Madison,
recalls, "With DOS, you could write a screen reader easy as
rolling off a log. Well, in Windows, it turned out to be not so
easy to write those programs. So this was a real problem."
     The impact of this problem threatened to escalate
dramatically in 1994, with the impending arrival of Windows 95,
the Microsoft Corporation's newest GUI operating system. Windows
95 promised to be much more competitive than previous Windows
products, and its unveiling was to be a major business event.
What would happen when the business and professional worlds were
dominated by software that used GUI exclusively?
     Judy Brewer, project director for the Massachusetts
Assistive Technology Partnership (MATP), remembers, "Particularly
from the middle of 1994 up through the fall, there started to be
an increasing stream of phone calls from around the state, from
blind computer users who were saying things like, 'I'm terrified
I'm going to lose my job; my department is switching to
Windows-how can I adapt to this?' And we'd have to say, 'Well,
we're not sure.' Or they were saying, 'I'm really frustrated-I
just lost a promotion, because to move up in my job I'd have to
be able to move to Windows.' Or somebody would say, 'I just lost
my job, because we've been unable to find an accommodation.' It
wasn't huge numbers, but given the low incidence of blindness
relative to other disabilities, it was very alarming. Here were
people who were very skilled computer users, and they were
getting bounced out of what had been a phenomenally good
technology to use: the combination of DOS and screen readers."
     As the release date for Windows 95 drew near, advocates
feared that blind computer users were about to face vocational
extinction.

Why Microsoft?
     It is a reflection of the company's success that the
Microsoft Corporation came to be at the center of the GUI crisis
and the focus of subsequent advocacy efforts. Microsoft products
dominate the world of GUI. The advent of Windows 95 promised an
enormous acceleration in the shift away from DOS and toward GUI.
     It is important to note here that disability advocates, and
NCD, have expressed concerns about GUI accessibility to companies
other than Microsoft. It should also be stressed that the
management of Microsoft was by no means opposed to greater
accessibility to computer products by people with disabilities.
Microsoft had, for example, worked with accessibility software
specialists to develop a variety of access aids for people with
limited dexterity. According to Greg Lowney, senior program
manager for the Accessibility and Disabilities Group at
Microsoft, Windows 95 was due to arrive on the market with
numerous accessibility features already written into the basic
operating system, even before the issue of GUI accessibility was
raised.
     Nevertheless, in terms of access for people with visual
disabilities, Microsoft was seen to be lagging. When people with
disabilities called their advocates with stories of how the move
to a new operating system was suddenly limiting their
opportunities, the systems they invariably mentioned were
developed by Microsoft. The irony, as Brewer points out, is that
"the highly accessible standard which screen reader users had
been accustomed to was in fact an earlier Microsoft product, MS
DOS. In other words, the essential problem was not the company,
but the technology, and then...the company's failure to respond
to concerns about its technology." Thus, despite the company's
success with other forms of computer accessibility, its
estrangement from blind computer users was near total.
     As Charles Crawford put it, "We were using Microsoft as the
primary target because they were the biggest developer of this
kind of software, and everything was going in the Windows
direction."

Early Awareness of the Problem
     Although the GUI crisis seemed to develop almost out of
nowhere, there had in fact been numerous warnings. Vanderheiden
was among the first to raise concerns about GUI, as early as
1985. Attempting to alert the blindness community, he took his
concerns to computer users in the major national blindness
organizations. For his efforts, Vanderheiden says he was "yelled
at and vilified." Blind computer users, he said, told him that he
could better spend his time developing better speech readers for
DOS-based systems or advocating for legislation prohibiting the
proliferation of GUI.
     "I did a conference in Madison (Wisconsin) several years
ago, and the question at the time was, Why would a person who is
blind want to use graphical user interface? The answer is that
they wouldn't, unless they had to. Back then nobody had to
because nobody was using Windows. But slowly, over time, Windows
came in."
     Another early warning voice was that of Susan Brummel,
director of the Center for Information Technology Accommodation
(CITA), at that time known as the Clearinghouse on Computer
Accommodations at the U.S. General Services Administration (GSA).
As early as 1988, Brummel and her office attempted to raise GUI
accessibility as an issue in federal purchases of software, after
the passage of the 1986 Rehabilitation Act Amendments charged GSA
with overseeing the implementation of Section 508 of the Act,
which required that federal agencies provide workers with and
without disabilities equivalent access to electronic office
equipment.
     "We push as hard as we can," says Brummel, "We wrote an RFP
[request for proposals] in the early 1990s that was intended to
be a model of [software] accessibility. We included language to
ensure that people with disabilities would be accommodated."
Brummel stresses that CITA, however, is "not the office that
keeps track of what agencies do and don't do. We're like the
people in the information window where somebody comes for an
application. We don't know who hasn't come to our window who
should have, and we don't know if they really fill out the
application or not once they take it away."
     Charles Crawford sent several letters on GUI accessibility
to the White House and the U.S. Department of Justice. In
September 1990, he wrote to President Bush "to share my serious
and growing concern....Simply put, developers of hardware and
software are not ensuring accessibility to their products...."
Crawford believed that Microsoft and other GUI
developers could facilitate accessibility by including
"hooks"-programming aids for screen readers imbedded in the
operating system itself. Failure to do so, he wrote, was a
violation of the recently passed ADA. "I ask that you refer this
letter to the Department of Justice Civil Rights Division for
their attention in conjunction with the General Services
Administration who have been working to resolve it." In a letter
from Justice Department dated November 26, 1990, Crawford was
referred to GSA, which "has issued guidelines in this area, and
continues to work with the computer industry on the issue."
Crawford notes, however, that he saw little progress in
addressing GUI access at the source: with the manufacturers of
operating systems.

The Crisis Develops
     Despite the early warnings, no major national advocacy
effort developed around the issue of GUI accessibility. No
national consumer organization made significant efforts to
confront the problem. The issue was, by and large, ignored by
the disability press and entirely unknown to most disability
rights advocates. Why?
     Gregg Vanderheiden believes that there was a certain amount
of denial in the blindness community's initial reaction.
Bringing up the issue of GUI accessibility, he says, "was like
telling somebody, 'Well, you know you're going to die.' No one
wants to deal with that." Nolan Crabb, editor and system
administrator for the American Council of the Blind's (ACB) World
Wide Web site and a software accessibility advocate at ACB, uses
the same analogy. "When someone is diagnosed with a terminal
illness, the first stage is denial. 'Oh this can't be happening.
The experts must be wrong.' And I think the blind community went
through a similar process."
     Crabb reports that ACB was aware that GUI would be a problem
"from the onset, as far back as the late eighties and early
nineties....We passed a variety of resolutions. Dialogue with
Microsoft was virtually impossible, because they weren't
listening." Despite this awareness, ACB did not undertake a
substantial campaign around the issue. "There was talk at one
time of picketing Microsoft headquarters, [but] no serious plans
were made. Microsoft began to change right about the time we got
to thinking that was a valid strategy."
     The National Federation of the Blind (NFB) also had trouble
coming to grips with GUI accessibility issues. Though it invited
representatives from the software industry to its conferences,
where the GUI issue was raised, there was never an effort to
force a showdown. In part, this had to do with the NFB's larger
technology agenda, as explained by Curtis Chong, president of the
NFB in computer science.
     "We were trying to counteract the overreliance and
overdependence on technology by rehabilitation people or people
who are blind, who thought of technology as the great savior of
the blind. And what we were saying in the Federation was
technology is great, but you still have to have your basic
blindness skills such as mobility and braille literacy....So for
us to deal with technology was a little difficult, because we
were trying to get them to stop putting technology at the top of
their list....We were trying so hard to get people to deal with
technology realistically, I think we almost tried too hard."
     The surprising speed with which Windows began to displace
other software systems was also a factor. Few anticipated that
the changeover from DOS to Windows in the mid-1990s would be so
sudden and so widespread. Microsoft itself was said to have been
caught by surprise. This element of surprise was exacerbated by
the fact that a parallel GUI product, the Macintosh operating
system, had not become the employment threat it had first
appeared to be because of its relatively slow acceptance in the
workplace.
     It was also difficult to develop a strategy that offered any
chance of success. Some consumers recognized the coming crisis
(at the NFB-sponsored U.S./Canada Conference on Technology for
the Blind in 1991, for example, and in the January 1994 issue of
Braille Monitor), but they were unable to get access to the
decision makers at Microsoft and the other major companies. And
whenever pressure from access advocates did begin to rise, their
efforts were short-circuited by assurances from Microsoft that
better access was coming.
     "Whenever there were the beginnings of sufficient pressure,"
says Brummel, "that would be capped with a meeting with a
Microsoft representative where they said, 'Okay, we hear you, and
this is what it's going to be, not to worry'." Speech reader
programs were promised for earlier Windows products (3.0 and
3.1), but when these were developed by independent software
developers, blind consumers complained that they were unreliable.
     "What I was hearing," says Judy Brewer, regarding the screen
reader situation in 1994 and early 1995, "was that of probably
eight screen readers on the market for Windows 3.1, two were
definitely better than all the others. And the best rating these
two got on the street was 80 percent efficiency. That's not good
enough to keep your job, if your job requires much computer use."
     Within the Federal Government, CITA held workshops and
training on software accessibility for numerous government
agencies. But even when RFPs were successfully negotiated with
software accessibility as a consideration, the results were
discouraging. Government purchasers had no way of verifying
contractor claims of accessibility, which were often overstated.
As Susan Brummel put it, "Nobody really knew until the tools
began to arrive at the employees' desks" if a software product
was truly accessible, by which time it was too late to change the
order.
     Finally, many people with and without disabilities, find
computers intimidating. Nolan Crabb at ACB and Curtis Chong at
NFB both report a division in their organizations between those
who are comfortable with computers and those who aren't.
Furthermore, in both organizations, computer access issues were
the exclusive purview of specific computer committees or
departments. These relatively small groups of computer
professionals and enthusiasts tended to work in relative
isolation, which lessened their organization's ability to respond
to the crisis in a timely manner.
     Ironically, this was a mirror image of the situation at
Microsoft, where all access issues were apparently relegated to
one person, Greg Lowney. Both consumer advocates and software
developers saw computer access as a technical issue isolated from
the concerns of the general organization. And so advocates for
information technology accessibility, in relative isolation from
the rest of their communities, brought their complaints about
Windows to Lowney, who was also toiling in organizational
isolation.

NCD's First Involvement
     NCD first addressed the issue of computer software
accessibility in its Study on the Financing of Assistive
Technology Devices and Services for Individuals with
Disabilities,
issued in March 1993. Two of the recommendations were to
"establish a Technology Watch program patterned after NCD's
current ADA Watch activities to monitor compliance with
enforcement of federal rights to or requirements for expanding
technology access for children and adults with disability" and to
"authorize by statute universal product design guidelines for
application in the manufacturing of electronic equipment and
other products to enhance accessibility by individuals with
disabilities." However, the report was not specific to
information technology, but concerned access to assistive
technology in general, including such items as durable medical
equipment, adapted telephones, hearing aids, and all kinds of
adaptive computing equipment for both children and adults.
     NCD had not been involved in any aspect of the GUI
accessibility issue. It was new Council member Bonnie O'Day who
first brought GUI to NCD's attention in the summer of 1994.
Herself a blind consumer, O'Day was familiar with screen readers
from personal use and had heard accounts of problems with Windows
from friends and other consumers. Jamal Mazrui, who had lost a
promotion at the Kennedy School of Government at Harvard because
of accessibility problems with GUI, became a volunteer with NCD
that summer, devoting his attention primarily to GUI
accessibility.
     An NCD meeting was scheduled in Seattle in late August 1994.
O'Day asked NCD send a letter requesting a meeting among NCD
representatives, high-level representatives at Microsoft, and
other concerned parties. The letter, dated August 8, 1994, and
addressed to Bill Gates, Microsoft chairman and CEO, "expressed
concern that Microsoft Corporation is currently in the process of
developing Windows based software that will be inaccessible by
computer professionals who are visually impaired or blind." It
asked for a meeting "to work toward an acceptable solution to
this issue."
     Among those present at the meeting on August 22, 1994, were
NCD representatives; and several future members of Tech Watch,
including Paul Schroeder (presently at the American Foundation
for the Blind, but at that time representing ACB) and Deborah
Kaplan (vice president and director of technology policy at the
World Institute on Disability). Also present was Deborah Cook,
assistive technology program manager at the Washington State
Department of Services for the Blind. None of the Microsoft
representatives present had the authority to make the policy or
budget decisions necessary to resolve the crisis. Instead,
advocates were told that, although GUI accessibility was a
difficult technical problem, Microsoft did not see itself as
responsible for resolving the problems. Little was accomplished
at the meeting, and advocates felt a deep sense of
disappointment.
     NCD sent a follow-up letter to Bill Gates on August 29,
1994: "While we appreciate the efforts of the programming staff
who met with us...we were extremely disheartened by the lack of
progress Microsoft is making in addressing this issue. Our
experience with monitoring the enforcement of the ADA in other
arenas leads us to conclude that a commitment to equal access is
vital from the very top of any organization. Therefore, we are
requesting a face-to-face meeting with you in hope that you will
make this commitment to us."
     It was several months before NCD received a formal reply.

Advocacy for Open Windows
     The next phase of GUI advocacy evolved in Massachusetts.
Charles Crawford at the Massachusetts Commission for the Blind
and Judy Brewer at the Massachusetts Assistive Technology
Partnership intensified their efforts to put pressure on
Microsoft.
     The goal, as articulated by Brewer, was twofold: "to
convince Microsoft to develop a screen reader applications
programmer interface (API), so that screen readers could more
effectively interpret information being sent to the screen; and
to convince Microsoft to incorporate that screen reader API into
their Windows logo program, which authorizes use of the Windows
logo on applications software marketing materials, so that people
purchasing applications software would know whether the software
in question used the screen reader API." One of the technical
problems presented by Windows was that, without such
standardization, it was virtually impossible for any one screen
reader program to work with the numerous Windows applications.
     Advocates examined three federal laws that might help in
their efforts to ensure GUI accessibility. These were ADA,
Section 508 of the Rehabilitation Act, and the Technology Related
Assistance For Individuals with Disabilities Act (the Tech Act).

The ADA
     Nothing in ADA that directly addresses the development,
manufacture, or purchase of inherently inaccessible information
technologies for the private sector, and none of the provisions
of the Act proved of immediate use to advocates in the GUI
crisis. Where an accessible computer might be considered under
the Act to be a reasonable accommodation, it was doubtful that
ADA would prohibit a large company from switching operating
systems from an accessible to an inaccessible interface if such a
switch affected only one or two employees or potential employees
in a large workforce. Similarly, to force a company that already
used Windows to switch back to a DOS or text-based operating
system would in most instances be "an undue burden" under the
law. Likewise, it was doubtful that the software used to run a
business could be considered a public accommodation.
     There was some possibility of addressing GUI accessibility
through Title II, which prohibits discrimination in services
provided by states or the Federal Government. For example, a
state employment office developing a data-base of job
opportunities would need, under Title II, to provide access to
blind users. However, Title II was of little or no help to
anyone working or receiving services in the private sector.
     The prospect of resolving the GUI crisis solely through ADA
enforcement or litigation seemed unlikely.

Section 508
     Section 508 was added to the Rehabilitation Act in 1986. It
states that federal agencies must provide workers with and
without disabilities equivalent access to electronic office
equipment. Theoretically, at least, Section 508 meant that
federal agencies could not go forward with the purchase of
inaccessible software, including GUI.
     Several federal agencies have made efforts to comply with
508, for example, the Veterans and Social Security
Administrations, but 508 has not resulted in GUI accessibility at
all agencies. Indeed, it is difficult to compile an overall
picture of federal compliance. Ken Pouloumes, director of
acquisition reviews at GSA, which is the agency charged with
monitoring 508 compliance, notes that "enforcement is handled at
the agency level, not at
the GSA level." His office did "look at enforcement for a number
of years, but we didn't get into the specifics with any software,
GUI or whatever." He reported that the only way to gather
information on 508 compliance as it relates to GUI accessibility
would be by "pulling specific RFPs" or calling individual
agencies "and asking them how they feel they've complied with the
Act." Lawrence A. Scadden, senior program director in Science
Education for Students with Disabilities at the National Science
Foundation and the principal author of 508, says the authors were
"naive, and so we didn't write in the teeth that it obviously
should have had" to adequately ensure compliance.
     Under 508, a private vendor who is unsuccessful in bidding
for a federal contract, can initiate legal action to stop or undo
a federal software purchase if the vendor can demonstrate that
its product was accessible, and the winning competitor's was not.
Theoretically, this provision could augment any enforcement of
508 within the Federal Government. To date, however, no such
suit has been filed. According to Brewer, legal action can also
be initiated "by an individual who is unable to obtain a
reasonable accommodation in a federally or state funded entity
because that entity has not procured information technology which
is consistent with Section 508."

The Tech Act
     The Technology Related Assistance for Individuals with
Disabilities Act was passed in 1988 and reauthorized in 1994 to
ensure that people with disabilities are able to obtain the
assistive technology they require in the settings where it is
needed. Title I provides for federal grants to be awarded to
states for the purpose of setting up statewide Tech Act projects
to address this problem. Currently, more than 50 such projects
are funded under the Act in the various states, districts, and
territories of the United States. These projects engage in a
range of activities including public education, information and
referral, training, technical assistance, policy development, and
direct systems change advocacy.
     The Tech Act mandates that state governments, before they
can receive their first extension grant for a fourth or fifth
year of funding under the Act, must certify that they are in
compliance or working toward compliance with Section 508. Thus,
the commitment to
accessible office technology is extended from the federal to the
state level, as spelled out in a legal opinion of the U.S.
Department of Education, handed down in August 1991 to all Tech
Act projects. This tie-in was to become crucial to GUI
accessibility advocacy. Through this language, the Tech Act
projects had, in effect, become enforcers of Section 508 at the
state, if not the federal, level.
     The Tech Act also stressed that projects must be consumer
responsive, which is a principal reason why Judy Brewer and MATP
took on GUI accessibility as one of their prime concerns. "We
were hearing loudly and clearly from the blindness community that
this was something that was very important to them. As a
consumer-responsive project, we felt we had an obligation to
respond." For four years, Brewer and other local advocates had
tried a variety of strategies, "with little positive outcome.
The most significant piece of early work was obtaining a
governor's executive order...which reiterated the principles of
Section 508 at the state level. We [MATP] also carried out
trainings of state agency ADA liaisons, provided technical
assistance on development of information technology RFPs, worked
with the Governor's Advisory Council on Information Technology on
the development of accessible PC standards," and so on.
     Crawford and Brewer set out in mid-1994 to convince their
state government that purchasing Microsoft's Windows 95 for its
offices would be a violation of Section 508 (specifically,
Massachusetts Governor's Executive Order 348) unless Microsoft
made certain changes to increase product accessibility. To this
end, they held a series of meetings with state officials, and
disability advocates from outside the blindness community, most
notably from the Massachusetts Office on Disability.
     Brewer said, "We took it to the Governor's Interagency
Coordinating Council on Disability Services in Massachusetts.
That group, as the heads of the various disability agencies, said
this is something serious and worth pursuing further. And they
authorized a series of meetings...with Administration and
Finance, the Department of Personnel Administration, the
Comptroller's Office, with anybody who had a piece in making the
decisions on major information technology procurements....Our
ability to point to a governor's executive order, with statutory
weight, helped greatly in our discussions within the state."
     Crawford added, "I had the idea that we ought to use the 508
compliance combined with ADA combined with the 508 requirement
under the Assistive Technology Act. I thought that if we
combined those three and then notified every state of that
requirement, we might create a sufficient economic block to draw
the attention of Microsoft."
     In October 1994, Crawford wrote a resolution on GUI
accessibility, approved by the National Council of State Agencies
for the Blind, that called for each agency to contact the
procurement officer for its state and insist that Section 508 be
enforced. NCD published the resolution on the Internet.
Simultaneously, Brewer's efforts in Massachusetts were drawing
the attention of other Tech Act projects across the country; 15
projects contacted her expressing interest in learning about and
possibly joining in an embargo, and a representative of
Massachusetts made it known that a multimillion-dollar contract
for Microsoft products would fall through if significant progress
were not made on GUI accessibility by July 1, 1995. The State of
Missouri did in fact institute an embargo on Windows 95 for
several months during this period. And, at the federal level,
CITA continued to stress the importance of 508 compliance.
Several major federal agencies, including the Social Security
Administration, began to examine ongoing negotiations for the
purchase of Microsoft Windows products in light of their
obligation to comply with 508.
     The GUI issue had also drawn international attention. The
efforts of European advocates such as Cearball O'Meadhra and
Ronan McGuirk, founders of the Visually Impaired Computer Society
in Ireland, made it evident that GUI accessibility was also an
issue to people who are blind and visually impaired in Europe.

NCD Efforts
     Ironically, the failure of the August 22 meeting at
Microsoft and the subsequent letter from NCD had the effect of
raising the issue to the upper management level at Microsoft.
Advocates had been concerned that accessibility issues at the
corporation were the exclusive purview of one individual: Greg
Lowney. While he was held in high regard and was considered to
be committed to accessibility, advocates believed that by
isolating access issues in this way Microsoft ensured that its
programs would continue to cause problems for blind
users. The consensus was that accessibility in software, as in
architecture or transportation, is best accomplished by
incorporating it into all facets of product design, across all
departments.
     The failure of the meeting also galvanized GUI advocates and
brought GUI accessibility to the attention of a much larger
segment of the advocacy community. Microsoft was seen to have
"snubbed" NCD, and advocates were irked that a major corporation
would treat NCD in this manner. It also made an impression with
the Massachusetts state procurement officials with whom Crawford
and Brewer were meeting, in that advocates could point to
good-faith efforts by the disability community to engage
Microsoft in a dialogue; efforts that had, apparently, been
rebuffed.
     NCD turned its attention to facilitating contacts between
accessibility advocates in the state and Federal governments.
Crawford and Brewer were invited to Washington to meet with
Barbara Silby, chief of staff at GSA. Brewer was given a rundown
of federal efforts at 508 compliance and the history of GSA
contacts with Microsoft, while GSA learned of the efforts of
Massachusetts and other states, and of the concerns of the
grassroots blindness community.
     The World Institute on Disability in Oakland, California,
had also been involved in GUI accessibility, having heard about
the problem both from its blind employees and from consumers in
the community. Deborah Kaplan's presence at the August 22
meeting was the Institute's first direct contact with Microsoft.
In December of that year, Kaplan attended a National Information
Infrastructure (NII) Advisory Council meeting, where she "made it
part of my agenda to talk with the Microsoft representative there
and to ask him why no reply had been received [to the NCD letter
of August 29]. I let him know that this was being interpreted
very negatively by the community, and that the community was
getting more and more upset."
     Gregg Vanderheiden too was in contact with Microsoft. "The
lack of response to NCD's letter, the way Microsoft dropped the
ball at the August 22 meeting, these had an impact. I let
Microsoft know that people were angry and would get angrier
unless something constructive was done."
     Meanwhile, the issue of GUI accessibility began to appear in
the mainstream press. The experience of Jamal Mazrui and other
consumers with Windows appeared in the Boston Globe on October
17, 1994. In March 1995, National Public Radio rebroadcast a
story on GUI aired in February by its local affiliate WBUR in
Boston. Articles about GUI accessibility problems also appeared
in computer-oriented magazines such as Computerworld and in
blindness publications such as Tactic magazine. Microsoft, in
the midst of marketing a new product, found itself the focus of
an increasing amount of negative publicity.
     GUI was now also becoming a hot item on the Internet, with
people who are blind and other consumers with disabilities
exchanging "war stories" and independent software developers
sharing their thoughts on what needed to happen to make Windows
accessible. Some of these messages were addressed to Microsoft
directly, others to Crawford, Brewer, or NCD. NCD began
collecting accounts from computer users whose lives had been
affected by the lack of GUI accessibility and added these stories
to the flow of information on the Internet.
     It is of course impossible to know which of these factors,
or what combination of factors, was decisive in influencing
Microsoft to change its stance in regard to GUI accessibility.
Many of the advocates interviewed believe that the threat of
state and federal embargoes, with the potential loss of tens of
millions of dollars in contracts, was the crucial factor. They
also point to the growing publicity and the messages to Microsoft
from advocates and consumers, explaining the impact GUI
inaccessibility had on their lives.
     "In the end," says Lowney, "the message was heard, and
that's really the important point."

Toward a Resolution
     The first verifiable indication of a change at Microsoft
came with a letter from Brad Silverberg, senior vice president of
the Personal Systems Division at Microsoft Corporation, to NCD,
dated January 25, 1995. In that letter, Microsoft made
commitments that offered hope for relief for blind computer
users.
     Silverberg wrote, "Personal computers are powerful tools
that enable people to work, create, and communicate in ways that
might otherwise be difficult or impossible. The vision of
enabling all people can be realized only if individuals with
disabilities have equal access to the powerful world of personal
computing."
     The letter represented a significant, even sweeping, change
in Microsoft's stance on GUI accessibility. In it, the
corporation agreed to put hooks in Windows programs "to allow
independent software vendors (ISVs) to develop third party
accessibility aids, especially those which allow blind
individuals to use Windows by way of a screen reader." Silverberg
said Microsoft would develop a software tutorial for blind users
and would hold an Accessibility Summit "where software vendors
would be invited to participate in an exchange of ideas and
experience creating products for people with disabilities. We
won't, however, rely solely on software vendors to do all the
work. Some additional utilities we'll build ourselves."
Silverberg sent a letter to Commissioner Crawford, with the same
list of commitments.
     In response to the letter, NCD sponsored a conference call
among Microsoft staff, disability leaders, and access advocates.
This teleconference reinforced the view among advocates that
Microsoft had indeed embarked in a new direction. In a February
21, 1995, response to Silverberg, NCD outlined a more specific
accessibility agenda for the corporation, agreed upon during the
conference call, that included issuing and then implementing a
Microsoft Corporate Accessibility Policy. Such a written policy
was unprecedented in the software industry.
     "I'd like to think we're making a radical shift," says
Lowney, "from where accessibility is really an afterthought to
entering a mindset where it's going to be something taken into
consideration in every project."
     Microsoft's Corporate Policy on Accessibility stipulates
that it "is the responsibility of everyone at Microsoft to
deliver on this commitment" to access. "Microsoft will devote
the time and resources necessary to ensure that an ever greater
number of users enjoy access to its products, technologies, and
services."
     "Windows is more accessible now than it was a year ago,"
says Mazrui. "And it looks like it will be more accessible next
year."
     However, the GUI accessibility issue is by no means
resolved: People who are blind and visually impaired are still
experiencing job dislocation because of Windows inaccessibility.
At least one screen reader for Windows 95 and an upgraded screen
reader for Windows 3.1 have appeared on the market, but there are
substantial problems with their reliability. And while advocates
generally have applauded the corporate policy statement, they
note that Microsoft hasn't met some of its own deadlines, and
they stress the need for continued advocacy. For example,
Microsoft has had problems developing some of the promised
accessibility components, such as the off-screen model, and might
postpone their delivery until later in 1996. It also became
clear at a November 1995 meeting between a Microsoft
representative and state agency heads in Massachusetts that
Microsoft had not filled the developer position for key
accessibility components, which had been open for more than 10
months. Massachusetts officials said they would review future
procurements in light of this information. Within two weeks,
Microsoft not only hired the developer but added several more
developers to its accessibility team in an effort to get back on
schedule. However, the community is still waiting for
Microsoft's commitment to GUI accessibility to be realized.

NCD: What Went Wrong, What Went Right
     Clearly, NCD could have been more proactive in addressing
GUI accessibility earlier than it did, although it is of course
impossible to know whether an earlier effort by NCD or other
advocates might have averted the loss of jobs and opportunity
that has occurred in the past two to five years. The same
factors that limited the responses of the national blindness
organizations may apply to NCD: Technology issues in general,
and computer issues in particular, are often difficult for lay
people to understand. Indeed, one commonly voiced complaint is
that the political leadership of the disability community lacks
computer literacy, even with the advent in the past decade of
assistive computer technology.
     It is also true that an issue, whether it involves civil
rights, consumer rights, technology, or any combination thereof,
generally do not receive political attention until it has
affected the lives of a large group of people. Crawford notes
that "most movements of
this kind sort of bubble until they reach critical mass, if they
ever do, and then they move forward. I'm not saying that [GUI
advocacy] shouldn't have happened earlier, but it's not
inconsistent with political history that it didn't. How many
accidents happened before Nader wrote his book Unsafe at Any
Speed? And then how long did it take after that to get some
consumer advocacy around cars?"
     Nevertheless, NCD could have more aggressively tracked its
own reports and recommendations. Two of the recommendations in
the March 1993 Study on the Financing of Assistive Technology
Devices and Services for Individuals with Disabilities-the
establishment of a Tech Watch project and NCD involvement in
developing "by statute universal product design guidelines" for
"electronic equipment and other products"-would most likely have
brought an earlier response to the GUI problem. The report
specifically mentions Section 508 as designed to "ensure that
people with disabilities can access and use the same databases
and application programs as other people." Had NCD taken steps
to reach out to the Tech Act projects in this regard, it seems
likely that the potential of Section 508 and the Tech Act for use
at the state level in GUI accessibility advocacy would have been
realized far earlier.
     However, it is clear that once NCD became involved, it made
several important contributions to the resolution of the crisis:
first the letter to and meeting with Microsoft in August 1994,
and then the follow-up letter to CEO Bill Gates. The effect of a
group of community representatives, appointed by the president,
taking an interest in GUI was to raise its prominence both in the
disability community and at Microsoft. NCD then played a crucial
role in facilitating the flow of information among state and
federal officials working on the issue. Its interest in 508
enforcement helped to invigorate efforts by Susan Brummel and
others at GSA, and GSA action added a national dimension to the
efforts of states such as Massachusetts and Missouri. NCD's role
in bringing state advocates to meet with GSA was also very
useful. According to Brummel, "Basically, what helped our agency
was to hear that [Massachusetts and] possibly other states might
move into an embargo or a partial freeze on [inaccessible GUI]
products." And NCD, by posting on the Internet technical
documents, reports of software advocates and developers, consumer
comments and accounts, and its own and Microsoft's
correspondence, became an important source of information.

RECOMMENDATIONS

     How can NCD help to implement GUI accessibility? How can it
help to prevent a comparable information technology crisis from
happening in the future?

1. NCD should establish a mechanism to ensure follow-up on its
     reports and recommendations.

     The establishment of a Tech Watch project was a
recommendation in NCD's March 1993 study on assistive technology
access. Almost two years passed before this recommendation was
implemented, more as a response to the GUI accessibility crisis
than to NCD's report. (In fact, this recommendation was not
specific to information technology, but rather referred to access
to assistive technology of all types. In this regard, it seems
the recommendation has yet to be implemented.) NCD should
consider ways to better monitor compliance with its
recommendations, especially those directed at itself. The
Council might include a follow-up mechanism in all future
recommendations, with specific persons or groups designated to
meet a timetable for progress reports to NCD. Or a committee or
task group could be given the responsibility to ensure follow-up
on all Council recommendations. In any event, NCD clearly needs
to better monitor its own reports and recommendations.

2. NCD should evaluate methods of ensuring Section 508
     compliance.

     NCD, as the federal entity charged with "reviewing and
evaluating on a continuous basis the effectiveness of all
policies, programs, and activities concerning individuals with
disabilities...and all statutes pertaining to federal programs,"
should consider methods of ensuring 508 compliance in the future.
This review becomes particularly important considering the
possibility that GSA may be removed from the picture entirely by
changes in federal procurement policy.
     To this end, NCD should form links with the various Tech Act
projects, which have a clear mandate to enforce 508 at the state
level, have had an enormous role in the resolution to date of the
GUI accessibility crisis, and possess a wealth of information on
technology accessibility and consumer needs and concerns. Such a
linkage would also help in the implementation of recommendations
5 and 6 below, in that the Tech Act projects, with their mandate
to be consumer responsive, are an important source of consumer
input and could be of great help in gathering data for any study
of information technology accessibility issues. NCD should
explore how these links could be established, with an eye toward
facilitating the Tech Act projects' ability to require 508
compliance by the states while NCD pursues strategies at the
federal level.
     In any case, NCD should continue to raise 508 compliance in
any appropriate forum. Finally, NCD should be aware that section
508 is due for reauthorization and might explore developing new
language for more effective enforcement.

3. Tech Watch, in consultation with other interested parties,
     should investigate the option of having the National
     Software Testing Laboratory (NSTL) develop an accessibility
     component as part of its systems testing. Efforts should be
     made to ensure that consumers are integrally involved in
     developing accessibility standards.

     Another recommendation made in the March 1993 report was
that NCD "authorize by statute universal product design
guidelines" for "electronic equipment and other products." In
terms of GUI accessibility in particular and software
accessibility in general, the most promising option in this
regard is an initiative by CITA to enlist NSTL, a division of
McGraw Hill in Philadelphia, to add accessibility to its testing
criteria. Software developers would submit their products to
NSTL, which would test and rate the product for accessibility.
State and federal agencies, when making software purchases, would
be able to use this benchmark to determine whether or not a
particular product, or combination of products, meets their
Section 508 requirement. Susan Brummel reports that the Canadian
government has already decided "to start looking at user
requirements, folding them into 1996 testing, and bringing people
with disabilities in to be a part of that."
     Whether or not the NSTL option is adopted, NCD Tech Watch
should be an integral part of any effort to develop software
accessibility standards. No other federal agency or national
disability group is in the position to provide the wealth of
consumer input needed to do the job right. Brummel has already
asked members of NCD to "help coordinate with the national
organizations of people with disabilities, to make sure that the
user requirements are derived from real users."

4. Tech Watch should make it an explicit policy to serve as a
     conduit of information among software consumers, advocates,
     researchers and developers.

     Through Tech Watch, NCD can bring together the recognized
experts on software accessibility, government, industry, and
consumer representatives, so that important issues can be
identified and possible solutions outlined before problems grow
to crisis proportions. Through Tech Watch, NCD can become a
forum for consumers, advocates, and industry, and a way for
information to pass among them. Industry would be better able to
see the impact of accessibility decisions, while advocates would
gain a better understanding of the realities and imperatives of
the software industry.

5. Tech Watch and NCD should consider how to use traditional
     methods of gauging community concerns (such as public
     hearings), and more recently developed approaches (such as
     Internet correspondence and chat groups), to gather
     information on technology accessibility issues.

     The fact that the major national advocacy organizations at
first missed the importance of GUI accessibility points to the
need for NCD to maintain its own close connections to the
community. Besides frequent contacts with technology
accessibility specialists, industry, and the representatives of
advocacy organizations, NCD also needs to hear from people with
disabilities, most of whom are not affiliated with any advocacy
organization.
     Charles Crawford believes that NCD "would do best to develop
a database of subjects and issues of accessibility, and have an
ongoing information process whereby people with disabilities
would be able to let NCD know what's going on in their lives. If
that sort of system is maintained, then you could generate trends
analysis to flag the things that need attention."
     During the GUI crisis NCD solicited, on the Internet,
personal stories from people who had been negatively affected by
GUI. NCD could repeat this call regarding other information
technology issues. NCD could also raise its profile with the
disability community, by soliciting input on technology issues
from the readers of disability publications, thus becoming known
as a place to bring concerns about information technology
accessibility. Tech Watch could schedule regular public hearings
on information access issues at various locations around the
country.

6. The information gathered should be used to prepare a report
     on possible future crises in software accessibility for all
     disability groups.

     One important contribution NCD could make would be to apply
the lessons of the GUI crisis and its resolution to software
accessibility issues affecting other disabilities. For example,
the accelerating proliferation of information kiosks threatens to
follow the same pattern as GUI. Few kiosk designers are
currently aware of accessibility issues or Section 508, or of
possible coverage of their products under ADA as public
accommodations. Kiosks using synthesized speech have the
potential to be inaccessible to deaf users; kiosks using
touch-panels have the potential to be inaccessible to people with
limited dexterity, low vision, or blindness. Some information
kiosks already in place are too high to use from a wheelchair.
If advocates wait until a substantial portion of the disability
community encounters problems with inaccessible kiosks, we could
once more have to play catch-up. For the same reasons, NCD
should use its influence to raise cross-disability access issues
on government and private World Wide Web sites, making sure that
kiosks are accessible from their first installation.
     Tech Watch should pursue a detailed study of possible future
software and information access issues. Consumers, software
accessibility experts, advocates, and industry should be
canvassed as to what on the information horizon might be of
concern. NCD could then repeat the role it took with GUI:
raising the issue at the highest echelons of product developers;
publishing the responses it receives; and setting up meetings
among industry, government, advocates, and consumers to resolve
the problems.

7. NCD, through Tech Watch, should continue to closely monitor
     Microsoft's efforts to provide access to its products.
     Follow-up with Microsoft and continued communication with
     the corporation's top management, are a must if the GUI
     accessibility issue is to be truly resolved.

                            CONCLUSION

     The rapid proliferation of personal computing and the
arrival of the information superhighway have already had a
profound impact on the lives of many people with disabilities.
Continuing technology breakthroughs have the potential for
empowering people with disabilities or for further limiting their
access to the mainstream of society. To ensure access, it is
imperative that people with disabilities participate in building
the NII.
     Such participation will not only empower people with
disabilities but will inevitably redound to the benefit of
society in general. Susan Brummel, in her white paper on NII
accessibility, notes that some of the most important information
technologies in use today were developed as a direct result of
research into accessibility. The telephone came out of research
on educating deaf children. The typewriter was invented to
enable people who are blind to write in print. E-mail was
developed by a computer scientist familiar with text transmission
because his wife was deaf and used a telecommunications device
for the deaf (TDD). Even when research into accessibility
doesn't immediately result in such world-shaking technologies, it
often expands everyone's horizons. The NII and its attendant
technologies should be no different.
     "If we demand higher standards of accessibility," says
Brummel, "we're not only helping our companies to be stronger, by
rewarding quality, but we're also ensuring that all our citizens
are well served."

                             APPENDIX

           MISSION OF THE NATIONAL COUNCIL ON DISABILITY

Overview and Purpose
     NCD is an independent federal agency led by 15 members
appointed by the President of the United States and confirmed by
the U.S. Senate.
     The overall purpose of NCD is to promote policies, programs,
practices, and procedures that guarantee equal opportunity for
all individuals with disabilities, regardless of the nature or
severity of the disability; and to empower individuals with
disabilities to achieve economic self-sufficiency, independent
living, and inclusion and integration into all aspects of
society.
Specific Duties
The current statutory mandate of NCD includes the following:
_ Reviewing and evaluating, on a continuing basis, policies,
     programs, practices, and procedures concerning individuals
     with disabilities conducted or assisted by federal
     departments and agencies, including programs established or
     assisted under the Rehabilitation Act of 1973, as amended,
     or under the Developmental Disabilities Assistance and Bill
     of Rights Act; as well as all statutes and regulations
     pertaining to federal programs that assist such individuals
     with disabilities, in order to assess the effectiveness of
     such policies, programs, practices, procedures, statutes,
     and regulations in meeting the needs of individuals with
     disabilities.
_ Reviewing and evaluating, on a continuing basis, new and
     emerging disability policy issues affecting individuals with
     disabilities at the federal, state, and local levels, and in
     the private sector, including the need for and coordination
     of adult services, access to personal assistance services,
     school reform efforts and the impact of such efforts on
     individuals with disabilities, access to health care, and
     policies that operate as disincentives for individuals to
     seek and retain employment.
_ Making recommendations to the President, the Congress, the
     Secretary of Education, the Director of the National
     Institute on Disability and Rehabilitation Research, and
     other officials of federal agencies, respecting ways to
     better promote equal opportunity, economic self-sufficiency,
     independent living, and inclusion and integration into all
     aspects of society for Americans with disabilities.
_ Providing the Congress, on a continuing basis, advice,
     recommendations, legislative proposals, and any additional
     information that NCD or the Congress deems appropriate.
_ Gathering information about the implementation,
     effectiveness, and impact of the Americans with
     Disabilities Act of 1990 (42 U.S.C. 12101 et seq.).
_ Advising the President, the Congress, the Commissioner of
     the Rehabilitation Services Administration, the Assistant
     Secretary for Special Education and Rehabilitative Services
     within the Department of Education, and the Director of the
     National Institute on Disability and Rehabilitation Research
     on the development of the programs to be carried out under
     the Rehabilitation Act of 1973, as amended.
_ Providing advice to the Commissioner with respect to the
     policies and conduct of the Rehabilitation Services
     Administration.
_ Making recommendations to the Director of the National
     Institute on Disability and Rehabilitation Research on ways
     to improve research, service, administration, and the
     collection, dissemination, and implementation of research
     findings affecting persons with disabilities.
_ Providing advice regarding priorities for the activities of
     the Interagency Disability Coordinating Council and
     reviewing the recommendations of this Council for
     legislative and administrative changes to ensure that such
     recommendations are consistent with the purposes of NCD to
     promote the full integration, independence, and productivity
     of individuals with disabilities;

_ Preparing and submitting to the President and the Congress
     an annual report titled National Disability Policy: A
     Progress Report.
_ Preparing and submitting to the Congress and the President
     an annual report containing a summary of the activities and
     accomplishments of NCD.
Consumers Served and Current Activities
     While many government agencies deal with issues and programs
affecting people with disabilities, NCD is the only federal
agency charged with addressing, analyzing, and making
recommendations on issues of public policy that affect people
with disabilities regardless of age, disability type, perceived
employment potential, economic need, specific functional ability,
status as a veteran, or other individual circumstance. NCD
recognizes its unique opportunity to facilitate independent
living, community integration, and employment opportunities for
people with disabilities by ensuring an informed and coordinated
approach to addressing the concerns of persons with disabilities
and eliminating barriers to their active participation in
community and family life.
     NCD plays a major role in developing disability policy in
America. In fact, it was NCD that originally proposed what
eventually became ADA. NCD's present list of key issues includes
improving personal assistance services, promoting health care
reform, including students with disabilities in high-quality
programs in typical neighborhood schools, promoting equal
employment and community housing opportunities, monitoring the
implementation of the Americans with Disabilities Act, improving
assistive technology, and ensuring that persons with disabilities
who are members of minority groups fully participate in society.
Statutory History
     NCD was initially established in 1978 as an advisory board
within the Department of Education (Public Law 95-602). The
Rehabilitation Act Amendments of 1984 (Public Law 98-221)
transformed NCD into an independent agency.



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