Whatever you think about current policies and practices regarding ICT accessibility, it’s generally agreed that we don’t know enough about consumers with disabilities that affect their use of ICT: how many, with what needs and preferences? What do they buy? What do they use, to accomplish what? What don’t they buy and use and do? Why, and what can be done about it?
The text below was submitted on April 6, 2015 by the undersigned disability and technology stakeholders regarding some proposed changes to the Census Bureau’s Current Population Survey on computer and Internet use that could answer some of those questions. We’re still looking for more support, so if you’re interested, please let us know in the ‘Leave a Reply’ box at the bottom to have your name and/or organization added to the signers, or email us to add your name. Also, please help us spread the word by linking to this page or using #a11ycounts.
- American Association on Health and Disability (AAHD)
- American Association of People with Disabilities (AAPD)
- American Council of the Blind (ACB)
- American Foundation for the Blind (AFB)
- Association of Assistive Technology Act Programs (ATAP)
- Autistic Self Advocacy Network (ASAN)
- Jon Avila
- Teresa Bellingar
- Reggie Bennett (Rebuilding All Goals Efficiently)
- Mary Brooner, MB Consulting, LLC
- Cisco Systems
- Henry Claypool, Claypool Consulting
- Consortium for Citizens with Disabilities Technology and Telecommunications Task Force
- Laura DeLancey, Western Kentucky University
- Lainey Feingold
- Global Initiative for Inclusive ICT (G3ict)
- Sheela Gunn-Cushman
- Illinois Assistive Technology Program
- Institute on Disabilities, Temple University
- Clayton Lewis, University of Colorado
- Louisiana Assistive Technology Access Network (LATAN)
- Valerie Maples
- Greta Menard, Concepts Communications
- Missouri Assistive Technology Council (MoAT)
- National Center on Disability and Access to Education (NCDAE)
- National Disability Rights Network (NDRN)
- Roy Nickelson
- Joseph Karr O’Connor (@AccessibleJoe)
- Pennsylvania Department of Labor and Industry
- Heydon Pickering
- Sarah Presley
- Raising the Floor International
- John Rochford (Clearhelper)
- Smart Steps 4 Me
- Kel Smith (Anikto)
- Telecommunications for the Deaf and Hard of Hearing (TDI)
- Trace Center, University of Wisconsin-Madison
- United Cerebral Palsy (UCP)
- Web Accessibility in Mind (WebAIM)
- Ann Cameron Williams, PhD (ao Strategies)
- Wireless Rehabilitation Engineering and Research Center (Wireless RERC)
- Vita Zavoli
- Inclusive Technologies
Text of Comments
The undersigned hereby submit the following comments regarding the Proposed Information Collection in a Computer and Internet Use Supplement to the Census Bureau’s Current Population Survey (http://www.gpo.gov/fdsys/pkg/FR-2015-02-04/pdf/2015-02087.pdf).
Even as the Internet becomes a crucial part of full social participation, we see that its usage growth is perhaps peaking at only 75% of US households . There is data to suggest that a significant percentage of those not currently using the Internet are excluded from it by usability and accessibility barriers, rather than, or in addition to, the conventional factors of price, relevance, institutional gatekeeping, and digital literacy. As the Wireless RERC pointed out in their comments on this issue in 2012, “From WRERC comments in 2012 , “NTIA’s own report, Exploring the Digital Nation – Computer and Internet Use in the Home , shows that people with disabilities are less likely to own a computer and have home broadband access.” Research for the FCC’s National Broadband Plan found that 39% of those without broadband at home had a disability .
Examples of these barriers are the many websites that are not compatible with screen readers, the online videos lacking captions and/or descriptive audio tracks, the heavy emphasis on graphical user interfaces in new mobile technologies, the confusing complexity of many technology products and indeed the Internet itself, and smartphones that pose handling and operational difficulties for people with impaired dexterity. These barriers, and previous negative experience with them, keep too many people with disabilities away from and pessimistic about an otherwise highly inclusive, opportunity-rich environment for education, employment, civic engagement, commerce, personal development and expression, and entertainment, costing our society tens or even hundreds of billions of dollars a year in commerce, personal income and thus tax generation, and entitlement reduction [4, 5, 6].
We strongly support the collection of data on computer and Internet usage by the Department of Commerce’s National Telecommunications and Information Administration (NTIA) as detailed in Federal Register Document 2015–02087, via a supplement to the Census Bureau’s Current Population Survey (CPS). The CPS is rightly the gold standard in US demographic data collection. We believe it can provide “practical utility” by informing NTIA and other agencies in their efforts to expand both the user base and the effective use of the Internet.
However, previous collection efforts have not done enough to provide the data granularity necessary to elucidate disability-related factors in non-usage. We believe this to be a key gap in informing both the ICT industry and public policymakers about how to increase and enrich the digital participation of people with disabilities. This was confirmed at a multi-stakeholder workshop held at the FCC on the topic on December 7, 2011.
Industry designers and developers need more detailed information about specific features and assistive technology usage patterns (or lack thereof) among the various disability segments if they are to continue their advances in creating more accessible ICT products. Simply knowing how many users (and non-users) with disabilities there are is not sufficient, if the information is aggregated across disability categories and degree of functional limitation.
Public agencies lack the data that should be driving decisions about policy and programs. A case in point is the current updating of Section 255 and 508 accessibility regulations. The Preliminary Regulatory Impact Assessment  cannot quantify many of the benefits of enhanced accessibility because there is a lack of data about how many people encounter what kinds of ICT barriers, in what environments of use, and how those potential users respond to barriers through assistive technologies and other solutions. It’s as if we are engaged in developing a public health response to a dangerous and fast-moving epidemic, but lack information about who the affected populations are, and what vectors of infection exist. This is all the more relevant as the nation is faced with an aging population and, as a result, a growing number of persons with disabilities as a percentage of the population.
Similarly, without data to drive policy and programs, efforts to attract and support new Internet users with disabilities have often been unfocused and unsuccessful. The same is true for the supply side of technology: ICT providers would benefit from a better understanding of how many people encounter difficulties in using their products.
We ask that the following recommendations be factored into the CPS data collection effort, and/or made the subject of equivalent study:
- A greater focus on factors leading to non-usage. As we transition out of the Internet’s rapid growth in user base, the “easy” phase of generating new Internet users, it becomes more and more important to understand why the remaining non-users are not signing up and logging in. Questions here should be driven by previous studies, with clear hypotheses that can affect public programs that seek to expand the Internet circle.
- Accessibility- and usability-relevant questions regarding non-usage. Previous methodologies have focused on respondent answers to the “Washington Group” questions about disability , then cross-tabulating those answers with the answers to usage questions. The Washington Group questions are excellent for many purposes, but here they do not reflect all disabilities relevant to computer usage; neither do surveys use the Washington Group questions to directly link any disability with specific reasons for non-usage. Moreover they do not, nor were they intended to, include issues of usability. We suggest that the survey design include a question or series that explicitly asks whether the respondent (or anyone in the household) has any difficulty—or believes they may have a difficulty—that would interfere with their use of a computer or the Internet, including learning to use a computer or the Internet and specifically what that difficulty is. Ideally this new battery should proceed from qualitative research (e.g. focus groups) in order to ensure relevance and semantic accuracy.
- Individual-level data. Surveys that ask only about household subscription and usage do not capture whether a household member with a disability also uses the Internet. Thus non-users with disabilities living in using households are omitted from analysis. This sampling issue is critical in our view, and needs to be resolved by CPS methodologists prior to data collection. A possible question would ask whether all members of the household use the computer and Internet resources, and if not all do so, ask about reasons for non-use.
- Full population basis. The CPS is not administered to “[p]eople in institutions, such as prisons, long-term care hospitals, and nursing homes” . This omits a large number and high concentration of people with disabilities living in group homes, assisted living facilities, and other living arrangements. If our goal is to increase total national adoption and usage, these citizens should be included in the survey results somehow. We call upon the study to clarify its exclusion or inclusion of both institutionalized and non-institutionalized residents, and to extend as far as possible its definitions so that they include more people with disabilities.
- Inclusive survey methodologies. Methods of collection limited to “computer-assisted telephone interviewing and computer-assisted personal interviewing” [FR 2015-02087] will automatically exclude many potential respondents who do not use voice communication, reject incoming calls from unknown callers, or prefer to avoid computer use situations for whatever reason. There are alternative channels and tools worth exploring to contact these millions of Americans with disabilities.
As the pool of Internet non-users shrinks, we believe that a growing percentage are or feel excluded by reason of inaccessibility or poor usability. Careful data collection can confirm this hypothesis and indicate appropriate design and policy solutions, in the spirit of the stated need “to identify problem areas with a specificity that permits carefully targeted and cost-effective responses.”
 Computer and Internet Use in the United States: 2013. ACS, 2014. http://www.census.gov/history/pdf/2013computeruse.pdf
 Wireless RERC Recommends Accessibility Concerns be Included in the NTIA CPS, 2012. http://www.wirelessrerc.gatech.edu/content/newsroom/wireless-rerc-recommends-accessibility-concerns-be-included-ntia-cps-supplement
 Exploring the Digital Nation – Computer and Internet Use in the Home, NTIA, 2011. http://www.ntia.doc.gov/files/ntia/publications/exploring_the_digital_nation_computer_and_internet_use_at_home_11092011.pdf
 Broadband Adoption and Use in America, John Horrigan; FCC, 2010. http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-296442A1.pdf
 The economic impact of digital exclusion; Econsult Corporation, 2010. http://www.digitalimpactgroup.org/costofexclusion.pdf
 Disability in the Digital Age, Pew Research Center, 2012. http://www.pewinternet.org/2012/08/06/disability-in-the-digital-age/
 Great Expectations: Potential Economic Benefits to the Nation From Accelerated Broadband Deployment to Older Americans and Americans with Disabilities, Robert E. Litan 2005. http://newmillenniumresearch.org/archive/litan_final_120805.pdf
 Section 255/508 Preliminary Regulatory Impact Analysis, Econometrica, 2015. http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/preliminary-regulatory-impact-analysis
 Washington Group on Disability Statistics; Short Set of Questions on Disability. Collected from http://www.cdc.gov/nchs/washington_group/wg_questions.htm