IAG Response for The White House Office of Science and Technology Policy (OSTP) Request for Information (RFI)

The White House Office of Science and Technology Policy (OSTP) issued an RFI seeking input from the public to help inform the development of the Federal Evidence Agenda on Disability Equity. Executive Order 14091 on Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government (February 16, 2023) directed the OSTP National Science and Technology Council Subcommittee on Equitable Data (SED) to coordinate implementation of recommendations of the Equitable Data Working Group. To address the recommendations relevant to disability, the SED established the Disability Data Interagency Working Group (DDIWG). The DDIWG is tasked with the development and release of a Federal Evidence Agenda on Disability Equity, in order to improve the Federal government’s ability to make data-informed policy decisions that advance equity for the disability community.

IAG’s Response for the OSTP RFI follows:

Members of the Information Architecture Gateway (IAG) and World Wide Web Consortium’s (W3C) Information Architecture Community Group (IACG) participate in the W3C Accessibility at the Edge Community Group (A11YEDGE CG). The mission of the W3C Accessibility at the Edge Community Group (A11YEDGE CG) is to examine improvements to Internet accessibility via “edge computing,” a relatively new paradigm that focuses on performing tasks at the edge of the network. Unlike cloud computing, edge computing emphasizes activities that occur closer to the user; these could include accessibility-oriented user-agent extensions, applications on content delivery networks, JavaScript-enabled capabilities, AI or ML. The W3C Accessibility at the Edge Community Group is a forum for discussing both currently available standards for products and potentially new applications not yet commercially available. as well as objective measures of quality of any one of these. The group’s tasks include inventorying, monitoring, and tracking both opportunities and challenges, drafting and incubating Internet specifications for further assessment, standardizing, prototyping and testing of reference implementations. A11YEDGE CG meetings work and operate under the W3C Code of Ethics and Professional Conduct.

The Information Architecture Gateway (IAG) is committed to accessibility. People cannot use a product, service, or information if they cannot access or find it. And in order for them to be able to access or find desired information, it must be designed, built, and operated with accessible methods.

The IAG  is a Science Gateway affiliated with the Science Gateways Community Institute (IACG). One main purpose of Information Architecture, Wayfinding, and Site Navigation is to enhance the effectiveness of user interfaces by supporting and enabling task completion, accessibility, learnability, and sustainability. 

According to the W3C, web accessibility means that websites, tools, and technologies are designed and developed so that people with disabilities can use them. Types of disabilities that the W3C recognizes are visual, auditory, speech, cognitive, neurological, learning, and physical. Below are some examples of each type of disability.

  • Visual. Problems with eyesight aren’t just focused on the function of our eyes, but also on how our brains perceive what our eyes. Visual disabilities include low vision, color blindness, and full blindness. One example of a visual barrier is a busy background, such as a photo with text on top of it. The text will likely be too hard to read.  A background that does not offer sufficient color contrast can also be difficult to read.
  • Auditory. Auditory disabilities range from mild-to-substantial hearing loss in one or both ears. For example, video content can only be fully accessible for hearing- impaired people if the video or video page contains subtitles or transcripts. People with an auditory disability may or may not be able to verbally communicate with voice technology and therefore may require assistance with voice activated technology. (see Speech)
  • Speech. People with speech disabilities often struggle with voice-based services. They might have difficulty producing speech that is recognizable by speech recognition software, which is software used with a microphone so that a computer can be operated with spoken commands. To work with websites, people with speech impairments require alternative modes of interaction such as text-based chat or keyboard commands. Certain conditions, injuries or medications may also temporarily impair or alter speech, affecting voice biometrics.
  • Cognitive, neurological, and learning. Cognitive impairments include difficulties with memory, attention, and information processing. One example of a cognitive disorder is dyslexia. Some neurological disorders are epilepsy and cerebral palsy. This group of disabilities also includes behavioral and mental health disorders that are not always neurological. They can be temporary, as with an accident, stroke or medication use, or permanent.
  • Physical. People with physical disabilities might have problems using a mouse, a keyboard, or a touchscreen, depending on their physical condition. Physical disabilities include weakness and limits of muscular control, limitations of sensation, joint disorders, pain that impedes movement (such as fibromyalgia), and missing limbs. Like the other categories of disability, physical impairment may be temporary or permanent.
  • Additionally, people might have multiple or complex disabilities. Suppose a person has 20/600 vision without contact lenses or eyeglasses, and also has rheumatoid arthritis. Therefore, this person has a visual disability (“legally blind”) and a physical disability. This person might prefer to use (a) screens with higher color contrast, and (b) physical and onscreen keyboards with larger touch targets.

Making websites and other digital information technologies accessible ensures that all potential users or site visitors, including people with disabilities, can easily access desired content.

Website accessibility includes, but is not limited to, the communication style of the text as well as the technical development of the website. Web accessibility depends on several components working together, including web technologies, web browsers and other “user agents,” authoring tools, and websites. 

In 2034, senior citizens will outnumber children in the United States. One of our members attended the Navigating the Future of Healthcare: Transformation, Measurement and Integration on July 9, 2014, where two speakers were from the National Institutes of Health (NIH) Veterans Administration (VA). According to the webinar content, the proposed transformation for future healthcare is having people manage or ‘be in charge” of their own healthcare. This self-directed care creates opportunities for autonomy and control on the part of the individual patients, but also introduces a layer of complication to the user experience for disabled individuals, care givers, and guardians.

Accessibility affects people of all ages and special groups such as Veterans. A person can have a temporary disability that is due to a side effect from a prescribed medication, from an accident, or from illness. Designing, writing, coding, programming, and building to accommodate accessibility issues is a critical goal of the Information Architecture Gateway (IAG). We recognize that accessible and age-friendly design have wider benefits than allowing people with disabilities to use websites. An example of a physical design is what User-interface researchers call the curb-cut effect, which refers to the fact that designs created to benefit people with disabilities often end up benefiting a much larger user group.

Many underprivileged groups do not have access to the Internet and often do not have phones that can accommodate task completion for healthcare interfaces or do not always have access to a shared phone. They may be unable to fill out required forms. Further, if they need assistance, they often are unable to talk to a live person to help them with their issues. Technology changes every day. A phone (device) might not support the technology that the government or a healthcare organization uses. People might have a phone but they might not be able to use the browser or other software required to complete their tasks. In addition, people may encounter chatbots, automated systems on phones that do not allow people to talk to a live person, or phone numbers that are hidden or non-existent on websites.

In other words, people with urgent needs might not have a phone that supports critical needs, access to the Internet, and the technology needed on the phone. Furthermore, if the only way people can access the Internet is through a public library, the Internet connections are not private. Therefore, privacy and security issues are common.

For guidance around issues of safety, security and access, refer to the Internet Safety Labs’ISL Safe Software Specification and the work on mobile identity authentication at Kantara Institute’s Resilient Identifiers for Underserved Populations Work Group and the DEIA Sub-Committee.

We do not know what technology we will be using in 2034. 

  • Interfaces
  • Cognitive
  • Physical issues
  • Technology disappearance
  • How to tactically use devices
  • AI will continue to unfold

All technology partner programs, financial institutions, and government, publicly funded business growth programs should be required to recognize sole proprietors and not discriminate against family-owned and small minority owned small businesses. Small businesses and nonprofits employ many disabled persons. Many small businesses start out as sole proprietorships and grow into larger businesses. Excluding sole proprietorships from programs limits an important startup option, and negatively impacts the business startup capacity of our larger economy, especially local business ecosystems.

Policies should be developed to require companies that contract with contractors in other countries that they should have contracts that assure the same non-discrimination and compliance requirements that the U.S. has when serving US citizens, especially with accessibility compliance. Foreign contracts should be bound to the same rules when serving U.S. citizens. There needs to be a simple way to report problems and complaints. There is a need for more external oversight and reporting requirements.

All contractors, especially non-US based contractors need to be more compliant with U.S. standards especially in the authentication and verification processes, providing access and especially including access options for caregivers, guardians, and parents. In all authentication and verification processes there needs to be a human in the loop so that a disabled person can always contact a human to work through any authentication and verification issues that may not be solvable by standardized systems. There should always be a way to contact a human to solve complex needs not accommodated by automated AI machines and robots.

Many big technology companies often bully small businesses, nonprofits, sole proprietorships, and family-owned businesses, generally not accommodating their particular needs, holding them to unrealistic, complex, overly technical requirements that do not apply to them, and can put them out of business. Many persons with disabilities work for small and family-owned businesses.

Deceptive practices are a challenge for everyone, especially persons with disabilities.  For example: Where does one find the place to cancel a subscription? There should always be a simple way to cancel a subscription. The method must always be made accessible to persons with disabilities. Many technology and online service subscription cancellation processes and methods are not accessible.

Disclosure: This submission was prepared by humans without AI or ChatGPT source references.

Respectfully submitted,

Noreen Whysel, Information Architecture Gateway (IAG), CUNY NYC College of Technology 

Shari Thurow, Information Architecture Gateway (IAG)

Chris Novell, Information Architecture Gateway (IAG)

Bev Corwin, Information Architecture Gateway (IAG)