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RESNA Policy Position Statement

Approved by the Board of Directors, December 2015

Executive Summary

RESNA, the Rehabilitation Engineering and Assistive Technology Society of North America, is the premier professional organization dedicated to promoting the health and well-being of people with disabilities through increasing access to technology solutions. RESNA serves a broad constituency with widely varying roles and interests. From that perspective, it endorses a number of broad policy principles, including, but not limited to, non-discrimination and inclusion of people with disabilities, access to appropriate and usable assistive technologies (AT), compatibility and interoperability between AT and the built environment and other technologies, professional development of and recognition for qualified AT professionals. RESNA also supports the involvement and participation of key stakeholder groups within AT and rehabilitation engineering research and development, manufacturing and supply, and distribution and provision, as well as service delivery.

More specifically, RESNA endorses eight key policy principles: 1) legislation, regulatory rulemaking, and policymaking to ensure disability rights in North America, including the United States, Canada, and Mexico; 2) legislation and policymaking to support rehabilitation and technology access; 3) legislation and policymaking to support AT access; 4) employment and educational opportunities for people with disabilities; 5) support for research, development, and training activities in the areas of rehabilitation engineering and AT; 6) provision of appropriate technologies and services for people with disabilities and support for professionals and industry partners who participate in its provision; 7) recognition of the role of industry partners in the design and manufacture of assistive and rehabilitation technologies; and 8) policies that promote coordination in the development of voluntary consensus standards in North America and beyond.

INTRODUCTION

RESNA’s membership includes, but is not limited to, rehabilitation and biomedical engineers, occupational therapists, physical therapists, speech-language pathologists, AT specialists, computer scientists and developers, inventors, researchers, educators, suppliers and manufacturers. RESNA also engages other stakeholders, notably consumers of services and end-users of AT, disability advocates supporting technology access and use, and legislators and policymakers who make decisions that impact AT access.

POLICY PRINCIPLES

RESNA serves a broad constituency with widely varying roles and interests. From that perspective, it endorses a number of broad policy principles related to people with disabilities and AT:

Non-discrimination of people with disabilities as a civil right, including reasonable accommodation in employment and access to public accommodations, government services, and information,
Inclusion and participation of people with disabilities in society and culture,
Access to appropriate and usable assistive technologies to support participation and inclusion in society, including, but not limited to, employment, education, and maximum independence of people with disabilities,
Compatibility and interoperability of assistive technologies with the built environment and other technologies,
Professional development and recognition of the key role of qualified AT professionals in the AT service delivery process,
Increase in the number of people with disabilities working in the field of rehabilitation engineering and AT,
Involvement of people with disabilities in decision making processes related to AT,
Support for rigorous research and development into invention, innovation, and transfer of AT, as well as empirical evidence for its efficacy,
Distribution and provision of technologies and services for people who need them through appropriate and equitable mechanisms, including insurance and reimbursement,
Supportive business environments for manufacturers and suppliers within a delicate yet essential industry, including separate benefits categories for assistive technologies, where appropriate,
Recognition of new models and initiatives that may exert a positive influence in the field, such as Universal Design, Usability, and Visitability.

In support of its mission, membership, and the communities it serves, RESNA offers the following Policy Position Statement:

I. Disability Rights

RESNA supports the Americans with Disabilities Act of 1990 and related legislation, regulatory rulemaking, and policymaking. As the United States’ foremost civil rights law prohibiting discrimination of Americans with disabilities and guaranteeing reasonable accommodations in employment, public accommodations, and commercial facilities, the ADA represents the foundation for advancing accessibility and inclusion of Americans with disabilities in society.

As an organization also representing members in Canada and Mexico, RESNA also supports legislation to ensure the full participation of Canadians and Mexicans with disabilities through the removal of barriers to employment, public transit, education, provincial and municipal government services and facilities, and other goods, services and facilities offered to the public. In the case of Canada, for example, RESNA supports provincial legislation toward these ends, most notably the Ontarians with Disabilities Act and Accessibility for Ontarians with Disabilities Act, 2005.

As an international organization, RESNA also supports broader efforts to ensure human and civil rights of people with disabilities. Specifically, RESNA endorses the United Nations Convention on the Rights of Persons with Disabilities (CRPD), which has been ratified in Canada and Mexico but not in the United States. RESNA also supports the general goal of the World Health Organization’s (WHO) GATE Initiative “to improve access to high-quality affordable Assistive Products” and has been participating in its activities. RESNA observes that such efforts also present opportunities to promote research on affordable AT and personal mobility, as well as habilitation, rehabilitation, and full societal inclusion via well-qualified and trained personnel.

While the rest of this document focuses on specific legislation and policy in the United States, the principles are applicable to similar policies in other countries represented by RESNA.

II. Rehabilitation and Technology Access Legislation

RESNA supports the Rehabilitation Act of 1973 and recognizes this law as the first comprehensive effort to end discrimination on the basis of disability in programs conducted by federal agencies, in programs receiving federal financial assistance, in federal employment, and in the employment practices of federal contractors. Most notably, RESNA supports Section 504 of the Rehabilitation Act, intended to ensure access to federal programs for Americans with disabilities. As a technology-oriented organization, RESNA also supports Section 508 of the Rehabilitation Act, which mandates that electronic and information technology developed, maintained, procured, or used by the federal government be accessible to people with disabilities, including employees and members of the public. RESNA also supports efforts to enact and enforce Section 508 through the U.S. Access Board and its Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) in support of Section 508 standards and Telecommunications Act Accessibility Guidelines.

RESNA also supports similar laws by states to uphold the principles of Section 508, and it supports commercial best practices, including voluntary standards and guidelines, for ensuring access to electronic and information technologies (EIT) and information and communications technologies (ICT). RESNA also affirms support for related legislation such as Section 225 (relay services), Section 255 (accessible telecommunications equipment and services), Section 710 (hearing aid compatibility), Section 716 (access to advanced communications equipment and services), and Section 719 (relay service support for individuals who are deaf-blind) of the Telecommunications Act and the Twenty-First Century Communications and Video Accessibility Act (CVAA), as well as efforts by the Federal Communications Commission (FCC) to uphold the principles of these laws.

In addition, RESNA supports the efforts of partnering organizations and stakeholders to promote equal access by people with disabilities to information and communications technologies, including the Consortium for Citizens with Disabilities (CCD). Notably, RESNA is a signatory to the Declaration on the Rights of People with Cognitive Disabilities to Technology and Information Access.

III. Assistive Technology (AT) Access

RESNA supports the Assistive Technology Act, which guides state-level efforts to ensure the provision of AT to individuals with disabilities of all ages through comprehensive statewide programs of technology-related assistance. RESNA supports full funding for the 56 State AT programs and the National Technical Assistance Project serving approximately 50 million Americans with disabilities.

RESNA also supports complementary efforts to ensure the effective implementation of Assistive Technology Act programs and projects. RESNA supports efforts to understand matters affecting the national network of Statewide AT Programs and to respond accordingly to critical issues that impact access to and acquisition of AT. In doing so, RESNA supports partnerships and coordination with federal agencies, including the Administration on Community Living (ACL) in the Department of Health and Human Services (HHS), and other organizations and entities on issues affecting access to and acquisition of AT. RESNA also supports relevant research and demonstration projects that increase access to and acquisition of AT, include state level activities for demonstration, loan, reutilization, and financing of AT, as well as the training, technical assistance, public awareness, coordination and collaboration, and transition related to those technologies.

IV. Employment and Educational Opportunities

RESNA supports legislation designed to create employment and educational opportunities for Americans with disabilities to ensure full participation of people with disabilities in the workplace and society more broadly. In addition to support for Title I and II of the ADA, the ADA Amendments Act of 2008, and Sections 501, 503, and 504 of the Rehabilitation Act, RESNA supports the broader Workforce Innovation and Opportunity Act (WIOA) and other legislation to ensure that people with disabilities have access to employment opportunities and advancement.

In addition to legislation and policymaking, RESNA supports the implementation of federal and state-level programs designed to promote the employment of people with disabilities and support the provision of AT and rehabilitation engineering services by qualified professionals. These include, but are not limited to, programs supported by the Office of Disability Employment Policy (ODEP) in the U.S. Department of Labor, including the National Center on Leadership for the Employment and Economic Advancement of People with Disabilities (LEAD Center), National Collaborative on Workforce and Disability for Youth (NCWD/Youth), Job Accommodation Network (JAN), Partnership on Employment & Accessible Technology (PEAT), and Employer Assistance and Resource Network (EARN). RESNA also supports the national movement called Employment First, which promotes systematic changes that result in increased community-based, integrated employment for individuals with significant disabilities.

As an organization that includes Canadians, RESNA also supports relevant Employment Equity Policy and Employment Equity Programs in Canada designed to ensure the participation, inclusion, and accommodation of Canadians with disabilities in the workplace.

RESNA supports provisions within the Individuals with Disabilities Education Act (IDEA) and Elementary and Secondary Education Act (ESEA) designed to ensure educational opportunities for students with disabilities, including access to reasonable accommodations and assistive technologies designed to facilitate educational access. RESNA also calls for the acknowledgement and support of AT professionals working in these settings.

V. Research, Development, and Training

RESNA supports federal programs to further research, development, and training activities in the areas of rehabilitation engineering and AT. These include, but are not limited to the National Institute on Disability, Independent Living, and Rehabilitation Research (NIDILRR) within ACL at HHS, Rehabilitation Services Administration (RSA) in the Department of Education, and National Center for Medical Rehabilitation Research (NCMRR) within the National Institutes of Health (NIH) at HHS. RESNA also supports more targeted research, such as the Education and Human Resources (EHR) Core Research (ECR) program and prior Research in Disabilities Education (RDE) program of the National Science Foundation (NSF) to broaden the participation of people with disabilities in science and engineering.

RESNA supports the continued funding and, where appropriate, expansion of basic, translational, clinical, and applied research into rehabilitation and assistive technologies. More specifically, RESNA endorses those federal research efforts designed to further rehabilitation engineering and AT research and development, including, but not limited to, the Rehabilitation Engineering Research Center (RERC), Rehabilitation Research and Training Center (RRTC), and Disability and Rehabilitation Research Project (DRRP) programs at NIDILRR, and other similar programs designed to facilitate AT approaches.

RESNA also supports policies that align with RESNA’s Research Guidelines, including user involvement, cross-disability and integrated mass market design (including universal design), applicability of disability research to discoveries in other domains, achievable translational goals that articulate improved functional and quality of life outcomes, and mixed and integrated research methodologies that recognize the personalized approach to interventions.

VI. Provision of Technologies and Services

RESNA supports the provision of appropriate technologies and services for people with disabilities, as well as appropriate support for the AT professionals and industry partners who participate in its provision. RESNA encourages policymaking that promotes the provision of AT and rehabilitation engineering services by qualified professionals. Quality indicators include, but are not limited to, the Assistive Technology Professional (ATP) and Seating and Mobility Specialist (SMS) certifications. RESNA supports policymaking by regulatory entities such as, but not limited to, the Centers for Medicare & Medicaid Services (CMS), which is designed to realize legislative mandates to ensure that citizens have access to appropriate technologies and services.

More specifically, RESNA expresses its support for the use of timely data to inform decision making and policymakers’ responsiveness to technological change and flexibility to address consumer needs and support service providers. Where possible, policies should remain consistent with the current state-of-the-art in technology and practices. RESNA supports the collection of better comprehensive case-based evidence, as indicators and outcomes data are needed to assist in the development of cost efficient policies.

In addition, RESNA supports policies that ensure flexibility and options for people with disabilities whose technology and rehabilitation service needs may be permanent yet changing across the lifespan. This principle includes allowing people to keep their technology, for example, as they transition from school to work or from home to an in-patient setting. In addition, AT professionals and other service providers and clinicians should be provided with appropriate options to make the best decisions in collaboration with their clients. Consumer Choice principles should be promoted in the decision making process for employment goals and AT options. Where possible, policymaking should respect the specificity of consumer experiences and acknowledge the individual nature of disability and rehabilitation outcomes and support the role of qualified professionals in technology service delivery.

RESNA also supports the policymaking that recognizes the roles and expertise of the specialized professionals responsible for the assessment, selection, and provision of AT and rehabilitation and habilitation devices and services, including, but not limited to, Assistive Technology Professionals (ATPs).

RESNA also supports policies that recognize the technological convergence that has occurred as AT features have become increasingly integrated within information and communications technologies (ICTs) more generally. Conversely, assistive technologies such as speech generating devices (SGDs) may now include additional functions, thus requiring policymaker appreciation for ongoing technological integration as well as the mainstreaming of accessibility functions through software contained on devices.

VII. Industry Support

RESNA recognizes the role of industry partners in the design and manufacture of assistive and rehabilitation technologies that enable people with disabilities to participate in society. RESNA acknowledges the delicate nature of markets for these technologies, and it supports policymaking designed to promote innovation and competition while ensuring the mutual benefit for all stakeholders. Where appropriate, RESNA supports separate benefits categories for those technologies distinguished by a reliance on customization and specialization, where suppliers are limited, and where there is heavy reliance on specialized expertise for its assessment, manufacture, and provision.

VIII. Standards Setting

RESNA supports policies that promote coordination in the development of voluntary consensus standards in North America and beyond, as well as representation in international standardization forums. RESNA participates in these activities through its Assistive Technology Standards Board (ATSB) and related standards committees, and it works through corresponding committees in the International Organization for Standardization (ISO).