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Public Policy

The goal of the Disability Policy Collaboration is to impact national public policy for people with developmental disabilities, including those with cerebral palsy and intellectual disability, and their friends, families and loved ones.

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Technology

Telecommunication Breakdown: An Overview of Challenges Facing Persons with Disabilities

The Goal: An Inclusive and Comprehensive Telecommunications Policy

In 1996, Congress passed Section 255 of the Telecommunications Act in order to foster access for America's growing disabled population to dozens of technological advances in the area of telecommunications that disproportionately favor the able-bodied.

Like the provisions of the Americans with Disabilities Act (ADA) of 1990, which called on public and private entities to increase physical access and provide equal opportunity in the workplace as well as to public services, this regulatory scheme had a simple goal in mind: to promote the social inclusion and independence of persons with disabilities.

A Blueprint for Access

Based on guidelines set forth by the federal Access Board, Section 255 required manufacturers and service providers to meet three key criteria1:

  1. Ensure that telecommunications products and services are accessible to people with disabilities, if "readily achievable" (determined on a case-by-case basis considering such subjective factors as the cost and nature of the action and the resources available).

  2. Provide documentation and information in accessible formats to consumers with disabilities, if readily achievable.

  3. Where products cannot readily meet "universal design" criteria at the manufacturing stage (such as flexibility of use, low physical effort, tolerance for error and perceptible instructions), entities must distribute accessibility features across product lines "in a manner that will maximize accessibility."

Although most able-bodied individuals and entrepreneurs have enjoyed major increases in productivity and more leisure time due to the advent of cellular phones, voicemail technology and teleconferencing systems, many persons with disabilities have been unable to share these benefits of the communications revolution.

Findings: Technical Challenges to Accessible Telecommunications

After seeking input of stakeholders in the telecommunications field, including the disability community, nonprofit and health organizations, private industry and government, the Federal Communication Commission (FCC) in September 1999 issued a report identifying several barriers to an inclusive communications policy.2 The complaints voiced by individuals in that report, drawn from the expertise and experience of various cross-disability constituencies, mirror those of volunteers of the California Foundation for Independent Living Centers and members of other disability advocacy organizations throughout California.

  1. Consumers who are hearing- or speech-impaired indicated they continue to have trouble accessing voicemail and interactive menu services that are largely incompatible with TTY (text-teletypewriter). TTY units-small keyboard devices with LCD displays that transmit text over phone lines-were not initially designed with voicemail in mind.

    The signal most of them use-called Baudot-transmits at no greater than 60 words per minute and has no error correction mechanism. Some TTY users can place and receive TTY messages on voicemail systems (VMS) without difficulty or with only minimal loss of characters, but others either can't get them at all or they are so riddled with errors from the recording that they are incomprehensible.

    The largest manufacturer of TTYs in the country, Ultratec, estimates that there are some 300,000 TTY users in the United States-more than 1% of the population.3 Stated simply, 1 in 100 people cannot communicate effectively using voicemail.

  2. Consumers who use telephone relay services (TRS) are unable to successfully communicate with automated response systems deployed by schools, banks, employers, universities and other public and private entities.

    Distinct from TTY, telephone relay services enable standard telephone users to communicate with deaf, hard-of-hearing, deaf-blind, or speech-impaired people who use a TTY. Users of TRS communicate through a trained intermediary who relays information received via a TTY. Relay operators are trained in speech-recognition to assist people with speech impairments. Calls are initiated through a publicly-funded 1-800 hotline.

    The main problem is that the average interactive menu on an automated response system does not provide adequate time for the relay operator to transmit the instructions to the caller and then retransmit the message back to the bank or school, etc. Other menus can be so fast that a person who has hearing loss or even minor cognitive impairment cannot process the information and respond quickly enough to get through a call. Even users of standard telephones who are blind or have a motor disability commonly complain they don't have enough time to press the proper buttons needed to select from a list of options.

    Perhaps more importantly, consumers with special health needs require access to a wide array of 800 numbers for their health needs and in their professional lives. For example, consumers with mobility impairments who are looking for work need Assistive Technology information and referral to identify and get funding for durable medical equipment. Parents of children with asthma or uninsured migrant workers seeking preventive care may use 800 lines to get vital information on treatment.

    When even able-bodied persons complain that one mistake made while interacting with automated response often terminates the call, can you imagine trying to input a credit card number to buy a holiday gift or a CD over the phone when you are blind or work through a relay service?

  3. Inflexible time limitations also affect users of Speech-to-Speech or users with speech impairments who call on their own. There isn't enough time available for those with a mild- to moderate-speech disability to have their words re-voiced to the automated system by a specially trained operator.

    People with the slightest speech impairments frequently find their responses are not recognized by voice automated response systems. Whether speech impaired users employ Speech-to-Speech operators or speak on their own, their attempts to make a phone call usually elicit a curt "Thank you and goodbye" from the automated system.

  4. Although many businesses and government entities provide an option for callers to reach a live operator, often none is available. Where no operator is available, most consumers with disabilities are trapped in a process of trial and error and finally just give up.

    Unfortunately, where automated response systems have a live operator option, they are only available if the caller is clever enough to get through a nearly impenetrable series of menu selections, rendering this service useless to those who need the operator the most. Indeed, public and private entities' collective goal of reducing caller dependence on costly paid telephone operators conflicts directly with their goal of providing access consistent with the mandate of Section 255.

Universal Design Principles

Universal design principles-which promote maximum access to products and services at their inception (rather than later when such access can be very costly)-provide simple goals for manufacturers to keep in mind as they strive to promote access and expand their market. North Carolina State University's Center for Universal Design describe the seven key principles as follows4:

  1. Equitable use
  2. Flexibility in use
  3. Simple and intuitive use
  4. Perceptible information
  5. Tolerance for error
  6. Low physical effort
  7. Size and space for approach and use

It seems that the assistive technology paradigms of "flexibility of use" and "tolerance for error" have not been met in the evolution of consumer communications products. It should be encouraging to manufacturers to learn, however, that meeting these criteria can help them expand their consumer base and increase sales of their goods. There are some 54 million persons with disabilities nationwide, and near-retirement Baby Boomers—many of whom are likely to acquire mobility, hearing or visual impairments and decreased strength-make up the majority of Americans today. As each of us ages, disabilities become more common.

Among the many manufacturers of automated response and voice mail systems commonly used by businesses -- such as Avaya, AVT, Key Voice Technologies, Dialogic and Esna Technologies - a few have taken steps to address the issues addressed here.

Key Voice Technologies: This Florida-based manufacturer of voice mail and automated attendant products has created systems that process calls in up to 9 languages simultaneously (callers have a menu of languages), and has created systems that are capable of processing calls made with TDD devices. The system treats tones generated by TDDs as a second language.

Esna Technologies: This messaging solutions company has developed "unified messaging" platforms that allow users to access voice, fax and e-mail messages from one application with the ability to forward voice and fax messages over the Internet, and reply to messages via e-mail. Their advanced computer telephone server, called Active Voice, also has text to speech and multi-lingual speech recognition capability.

DiRAD Technologies: This voice messaging systems company which works directly with manufacturers to help them retool products and thereby expand market share, has developed a TTY-accessible VMS component that can be installed on top of a company's existing voice mail system, making it instantly accessible to TTY users. The company, which declares itself committed to "open standards" and the fusion of "voice, data and video networks," has recently been enlisted by AT&T to help them render their products more accessible.

Action Steps for VMS and Automated Response Manufacturers

The objective should be to create a nationwide telecommunications network that is free of barriers, setting an example for the world of just how far technology can go and allowing more and more Americans to reach out and touch someone. The goals of Section 255 cannot be achieved without greater understanding of the various physical and mental conditions that make current systems so problematic, as well as feedback from individuals who have been excluded.

First, providers and manufacturers of voicemail services and automated response systems should collaborate with makers of TTY systems as well as users of TTY, Speech-to-Speech and TRS to see that there is greater tolerance for error and more forgiving time constraints. In addition, they should produce documentation specific to consumers with disabilities that instructs them on how to avoid current challenges.

Voicemail providers whose systems are problematic for TTY users should solicit input from various cross-disability groups -- such as the National Council on Independent Living, the American Association of Retired Persons, Gallaudet University and the American Foundation for the Blind and National Federation of the Blind - to identify challenges. They should also emulate criteria currently used by private VMS systems that seem to function well with TTYs.

Second, manufacturers and users of VMS and automated response must recognize that certain groups - such as those with severe cognitive impairments - rely completely on operator services. These services should always be available, and callers should not have to go through a maze of confusing instructions to get to them.

But this is not a complete solution, either. In addition to providing a live operator option, they must continue to try to expand the number who can access automated systems. The long-term damage to the disability community of relaying on operator service to get equal treatment while the able-bodied rely on high-tech voicemail and automated response systems is that the "digital divide" becomes even greater.

In today's world, where familiarity with technology is rapidly becoming a necessity, the inability of persons with disabilities to participate has catastrophic ramifications. This is particularly true since they already lag far behind in computer technology where websites are unreadable to the blind and the most complex software applications are limited to the use of the few.

Looking to the Future

Accessibility continues to be a round-the-clock challenge for all of us. As new technologies emerge, there is an ongoing need to expand coverage of the Telecommunications Act so that persons with disabilities aren't always two steps behind the able-bodied population. We must work together to make the real, attainable reforms so that a barrier-free telecommunications network will one day become a reality.

147 U.S.C. 255 (Telecommunications Act of 1996)
2FCC Public Notice. Reminder to Manufacturers and providers of voicemail and interactive menu products and services of their accessibility obligations under new part 7 of the commission's rules.
3Jim Tobias, TTY Access to Voice Services Background Paper. Inclusive Technologies, May 9, 2000.
4Seven Principles of Universal Design. NC State University, The Center for Universal Design.