Toward Universal Accessin the Workforce

Development System

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A B A C K G R O U N D P A P E R

Toward Universal Accessin the Workforce

Development System

PAPER PREPARED BY:Curtis Richards

National Collaborative on Workforce and Disability for Youth

August 2005

This document was developed by the National Collaborative on Workforce and Disability for Youth, funded by agrant/contract/cooperative agreement from the U.S. Department of Labor, Office of Disability Employment(Number #E-9-4-1-0070). The opinions expressed herein do not necessarily reflect the position or policy of the U.S.Department of Labor. Nor does mention of tradenames, commercial products, or organizations imply theendorsement by the U.S. Department of Labor.

The National Collaborative on Workforce and Disability for Youth (NCWD/Youth) is composed of partners withexpertise in disability, education, employment, and workforce development issues. NCWD/Youth is housed at theInstitute for Educational Leadership in Washington, DC. The Collaborative is charged with assisting state and localworkforce development systems to integrate youth with disabilities into their service strategies.

Individuals may produce any part of this document. Please credit the source and support of federal funds.

NCWD/Youth877-871-0744 (toll free)

877-871-0665 (TTY toll free)www.ncwd-youth.info

contact@ncwd-youth.info

Toward Universal Access in the Workforce

Development System

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IntroductionThe word “universal” has multiple meanings andusages across the workforce development system; thesemultiple meanings have substantial implications forstudents, job seekers, employers, and the variousinstitutions providing services. Some people use theterms “universal access” and “universal design”interchangeably, because one has evolved from theother. Others use the term “universal access” whenreferring to “universal service.”

This paper explores the core concepts of “universalservice,” which has a very distinct meaning inside theemployment and training arena, and that of “universaldesign” in the context of disability public policy. Inaddition, this paper urges the adoption of acomprehensive definition of universal access thatwould apply across all titles of the WorkforceInvestment Act (WIA) to all programs and services inthe One-Stop system and incorporate elements ofuniversal access, universal service, architecturalaccessibility, programmatic accessibility, and universaldesign, as defined in the disability policy arena.

As the workforce development system strives to meetthe diverse needs of all its customers, particularly

youth and adults with disabilities and those for whomEnglish is not the primary language, a clearunderstanding of both universal service and universaldesign—and the ways they affect delivery of programs,services, and activities—is imperative. While both arestill emerging concepts in terms of how they effect theimplementation of the workforce development systemin this country, “universal access” is quickly becominga familiar concept at the local, state, and national levels.The term “universal access” has been introduced intothe workforce development system pursuant to theWIA as a means for ensuring that everyone has accessto the One-Stop system and to core employmentservices. The technical definition of “universal access”under WIA is narrow, referring to the obligation on thepart of recipients of WIA funds to make reasonableefforts—including through advertisement, recruitment,outreach, and targeting—to include participation ofpersons with disabilities in their programs andactivities (U.S. DOL WIA Section 188 Checklist).However, when this definition is viewed in conjunctionwith the WIA nondiscrimination, equal opportunity,and effective communication requirements, WIAprovides a framework for the broader definition ofuniversal access proposed herein.

Toward Universal Access in the Workforce

Development System

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It is time to put forth a definition of universal accessthat applies across the Workforce Investment Act titlesand to all programs and services in the workforcedevelopment system. Therefore, for the purposes ofattempting to create clarity throughout the system,NCWD/Youth proposes the following definition ofuniversal access: the design of environments, products,and communication as well as the delivery ofprograms, services, and activities to be useable by allyouth and adults, to the greatest extent possible,without adaptation or specialized design. In essence,this definition offers a common term that contains twoparts, the physical and the abstract, the visible and theinvisible. It is about both design and service delivery,and it captures the core concepts across the system.

Universal Access in the Workforce SystemThe concepts of universal access and universal design,from a disability policy perspective are now folded intothe federal Workforce Investment Act (WIA) and areapplicable to the entire workforce development system.

Access for people with disabilities is driven, in largepart, by some very specific standards embedded inmultiple laws and implementing regulations, such asthe Americans with Disabilities Act, Sections 504 and508 of the Rehabilitation Act, and now Section 188 ofTitle I of the WIA. Section 188, which implements theAct’s non-discrimination and equal opportunityprovisions, is applicable to programs, services, andactivities receiving financial assistance under the Title,and is patterned after, and in fact refers to, similarnondiscrimination statutes. Because of the stringency ofSection 188 coupled with Sections 504 and 508 of TitleIV, the WIA legislation is arguably one of the strongestcivil rights laws on the books.

Through guidance offered with the final WIAprogrammatic regulations, the concept of universalaccess indicates that “any individual will have access tothe One-Stop system and to core employment-relatedservices” as well as to information, instruction, andinterview opportunities (U.S. Department of Labor,1999). Section 188 regulations require recipients of WIATitle I financial assistance to take appropriate steps toensure that they are providing universal access to theirprograms and activities for people with disabilities. As discussed previously, the “universal access”

provisions of WIA require recipients of federal financialassistance to make reasonable efforts (includingadvertisement, recruitment, outreach, and targeting) toinclude participation of persons with disabilities in theirprograms and activities (U.S. Department of Labor, 1999).

Under the Workforce Investment Act, recipients offederal financial assistance also have an obligation toprovide reasonable modifications and reasonableaccommodations for and effective communicationswith people with disabilities. In addition, WIA imposesobligations relating to physical and programmaticaccessibility, which are discussed in greater detail laterin this paper.

WIA’s commitment to disability civil rights extends wellbeyond Title I. Another change that occurred with thepassage of WIA was the folding of important disabilitypublic policy and programs into the federal workforcestatute. Title IV of WIA contains the Rehabilitation ActAmendments of 1998, which authorize the entirevocational rehabilitation program as well as thesupported employment and independent livingprograms. It also incorporates by reference Section 504of the Rehabilitation Act, the precursor to the Americanswith Disabilities Act, as well as the full text of Section508, which requires federal agencies to ensure theaccessibility and usability of their electronic andinformation technology (Workforce Investment Act, 1998).

Thus, there are a number of federal laws andimplementing regulations that, taken together,recognize the need to ensure physical andprogrammatic access to people with disabilities as wellas the concepts of universal access, and non-discrimination and equal opportunity. Achievinguniversal access under the broader definition promotedherein, however, will require substantially differentapproaches to the design of instruction, services,materials, products, communications, locations, andenvironments, as well as new forms of professionaldevelopment for personnel of service providers.

A Brief HistoryAs noted earlier, it is important to make a distinctionbetween “universal design” and “universal access”—two terms that are often used interchangeably. Theformer is the more long-standing term and enjoys

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multiple examples of success in practice. The latter isevolving from the former and has a broaderapplication.

The concept of universal design originated in the fieldof architecture and initially focused on the builtenvironment and access to a facility by someone with aphysical disability. The term has since grown and beenapplied to other fields including product design,computer technology, electronics, telecommunications,classroom instruction, and workplace design.

The move toward universal design began in the 1950swith a new focus on disability in many societies. InEurope, Japan, and the United States, a concept knownas “barrier-free” design developed to remove obstaclesin the built environment for people with physicaldisabilities at the same time that public policyemphasized moving people with disabilities frominstitutional to community settings. Barrier-free designaddressed the special needs of a segregated population

of individuals, those with physical limitations andmobility impairments (Fletcher, 2002).

“Barrier-free” design became “accessible design” by the1970s as community integration of people withdisabilities began to take hold and the disability civilrights movement made design a civil rights issue forthe first time in history. Disability civil rights laws andregulations that began to spring up specified theresponsibilities of designers, owners, and publicagencies to make their facilities accessible, but stillfocused almost exclusively on the needs of people withmobility impairments and physical disabilities. “Lawsgoverning accessible design had reduced design to aset of minimum requirements,” explains ValerieFletcher, executive director of the Massachusetts-basednonprofit Adaptive Environments, Inc. “The lawsoffered invaluable protections but had the unintendedconsequence of diminishing attention to the creativepotential of design to enable users” (Fletcher, 2002).

DISABILITY ACCESSIBILITY CONCEPTS AT-A-GLANCE

Late 1980s Universal Design Architecture, Public Policy,Product Development

Built Environment, Disability Policy

1990s Universal Access Information Technology Hardware, Software,Internet

Today Universal Access Public Policy, WorkforceDevelopment System

Programs, Services,Activities, Facilities,Technology, Information,Communication

Source: Table based on Bowe, 2000; Fletcher, 2002; Rose & Meyer, 2002.

Time Period Accessibility Concept Industry/Field Application

1970s Accessible Design Architecture, Public Policy Facilities, CommunityIntegration, Disability CivilRights

1950s Barrier Free Design Architecture Built Environments

1970s Universal Design Architecture, ProductDevelopment

Remove EnvironmentalBarriers

1990s Universal Design Product Development Personal Use Products,Technology

2000s Universal Design forLearning

Schools Education, Instruction,Learning Environments

TABLE 1

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In the 1970s, an American architect, Michael Bednar,introduced the idea that everyone’s functional capacityis enhanced when environmental barriers are removed.He proposed that it was time for a new concept beyond“accessible design” that would address a broader arrayof issues and be more “universal” (Fletcher, 2002). Bythe late 1980s and early 1990s, Ron Mace, an Americanarchitect with a disability and founder of the Center onUniversal Design at North Carolina State University,began using the term “universal design” in the contextof “accessible design.” As Fletcher explains, Mace“made the case that universal design is ‘not a newscience, a style, or unique in any way. It requires onlyan awareness of need and market and a commonsenseapproach to making everything a design and productusable by everyone to the greatest extent possible’”(Fletcher, 2002).

According to Frank Bowe, “the idea was that ifusability could be marketed to the general public asconvenient, it would sell itself. People who try wide-grip scissors or other kitchen utensils, such as FriendlyFit forks and spoons…often prefer them to conventionalimplements; they just feel better.” He explains that itwas Mace’s idea that “if he could present universaldesign so that people would voluntarily adopt it, theworld would become a much more livable place for allof us” (Bowe, 2000).

Evolving DefinitionsThere are many definitions of universal design, as theconcept has grown and changed over time. The follow-ing definition of universal design—”The design ofproducts and environments to be usable by all people,to the greatest extent possible, without the need foradaptation or specialized design”—comes from Maceand his colleagues and serves as the foundation uponwhich others are still building. As Bowe points out, thisdefinition recognizes that universal design, doneproperly, benefits all kinds of people. It “is a majorconceptual break from the traditions of assistivetechnology” because it recognizes “that people canencounter problems in their environments for reasonsrelated to the circumstances in which they find them-selves; those problems are not qualitatively differentfrom similar problems that people with disabilities facebecause of their impairments” (Bowe, 2000).

Universal design has also been described as “theprocess of designing products, environments, andsystems so that they are usable by people with thewidest possible range of abilities and circumstancesgiven current technological and commercialconstraints” (Vanderheiden, 1996).

A broader definition of universal design is embeddedin the federal Assistive Technology Act of 1998 (PL. 105-394). According to the AT Act, which wasrecently reauthorized in 2004, “universal design meansa concept or philosophy for designing and deliveringproducts and services that are usable by people withthe widest possible range of functional capabilities,which include products and services that are directlyusable (without requiring assistive technologies) andproducts and services that are made usable withassistive technologies” (Assistive Technology Act, 2004).This definition takes universal design well beyond thebuilt and industrial product design environments, andbegins to apply it to services as well.

Recognizing that current definitions of universal designare somewhat limiting, Adaptive Environments, Inc.,one of the world’s leading research, training, andeducation organizations on universal design, hasrecently begun to articulate a new definition. Adaptive Environments states that “universal designincludes [not only] the design of places, things andcommunication but also policies, programs andservices” and should be viewed from a functionalability perspective (http://www.adaptiveenvironments.org). This relatively new developmentextends the concept well beyond the AT Act definitionand, more importantly, focuses attention on everyone’s abilities rather than on accommodatingdisabilities.

Applying Universal DesignAdaptive Environments explains that universal designis a way of thinking about design that is based on thefollowing premises:

• Varying ability is not a special condition of the fewbut a common characteristic of being human andeveryone changes physically and intellectuallythroughout life;

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• If a design works well for people with disabilities, itworks better for everyone;

• At any point in life, personal self-esteem, identity,and well-being are deeply affected by the ability tofunction in the physical surroundings with a sense ofcomfort, independence and control; and,

• Usability and aesthetics are mutually compatible.

Universal design asks from the outset how to make thedesign work beautifully and seamlessly for as manypeople as possible. It seeks to consider the breadth ofhuman diversity across the lifespan to create designsolutions that work for all users. (Fletcher, 2002)

There are seven generally agreed upon principles touniversal design developed by the Center for UniversalDesign at North Carolina State University (Center forUniversal Design, 1997):

1) Equitable Use: The design does not stigmatize ordisadvantage users.

2) Flexibility in Use: A wide range of individual pref-erences and abilities can be accommodated by thedesign.

3) Simple, Intuitive Use: How to use the design is easyto understand regardless of the experience, knowl-edge, language skills, or current concentration levelof the user.

4) Perceptible Information: Information is effectivelycommunicated to the user, regardless of the user’ssensory abilities, or surrounding conditions.

5) Tolerance for Error: Adverse consequences of accidental or unintended actions are minimized bythe design.

6) Low Physical Effort: The design is used efficientlyand comfortably with a minimum amount of fatigue.

7) Size and Space for Approach and Use: Regardlessof the user’s body size, posture, or mobility, appro-priate size and space is provided for approach, reach,manipulation, and use.

Appendix A to this background paper, labeled “KeyConcepts of Universal Design,” is a helpful table thatadds commonly understood definitions and guidelinesto each of the above referenced principles. Based on the

work of Frank Bowe and that of the Center onUniversal Design, this table was developed to serve asa technical assistance tool in the application ofuniversal access throughout the workforcedevelopment system.

The Assistive Technology Act contains a few otherdefinitions relevant to this discussion. It defines“assistive technology” as “technology designed to beutilized in an assistive technology device or assistivetechnology service.” In addition, “assistive technologydevice” is defined as “any item, piece of equipment, orproduct system, whether acquired commerciallymodified, or customized, that is used to increase,maintain, or improve functional capabilities ofindividuals with disabilities.” These terms arefrequently used interchangeably and it is common touse the term assistive technology when referring toboth. Similarly, “assistive technology services” isdefined as “any service that directly assists anindividual with a disability in the selection, acquisition,or use of an assistive technology device” and the termincludes “purchasing, leasing, choosing, designing,repairing, etc., assistive technology devices” (AssistiveTechnology Act, 2004).

Whereas universal design alters the environment andinformation, assistive technology allows individuals toadjust to an unaltered environment or informationsource and provides access to materials and services topeople with disabilities that would not otherwise beaccessible. Examples of assistive technology includewheelchairs, alternative automobile controls,communication aids, and hearing aids, plus a variety oftechnologies that increase, maintain, or improve accessto electronic and information technology forindividuals with disabilities. For example, people withlimited hand function may use a keyboard with largekeys or a special mouse to operate a computer; peoplewho are blind may use software that reads text on thescreen in a computer-generated voice; people with lowvision may use software that enlarges screen content;people who are deaf may use a TTY (text telephone); orpeople with speech impairments may use a device thatspeaks out loud as they enter text via a keyboard.

As described earlier, under the concept of universaldesign people with disabilities are not expected to have

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to alter the programs, services, products, environments,and communication. In contrast, assistive technology isused on an after-the-fact basis when someone with adisability cannot use a given product or service.Policymakers and program administrators should notethat the need for after-the-fact, specializedaccommodations can be reduced or eliminated entirelydepending on the disability, if universal designprinciples are employed to ensure that programs,services, and activities are, in fact, accessible to anduseable by the widest range of citizens.

Technology AccessA good example of the application of universal designappears in the area of access to technology. The federallaw governing electronic and information technologyaccessibility for people with disabilities was recentlybroadened, and detailed standards have beenestablished by the responsible federal agency, theAccess Board. Section 508 of the Rehabilitation ActAmendments of 1998—as a little noticed part of WIA—requires that electronic and information technologydeveloped, procured, maintained, or used by thefederal government be accessible to people withdisabilities. Federal employees and members of thepublic who have disabilities must have access to anduse of information and services comparable to theaccess and use available to non-disabled federalemployees and members of the public.

The standards established by the Access Board coverthe full range of electronic and information

technologies in the federal sector, including those usedfor communication, duplication, computing, storage,presentation, control, transport, and production. Thisincludes computers, software, networks, peripherals,and other types of electronic office equipment. Thestandards define electronic and information technology,in part, as “any equipment or interconnected system orsubsystem of equipment, that is used in the creation,conversion, or duplication of data or information.” Thisbroad definition covers all telecommunications devicesincluding telephones, voice-mail systems, pagers,facsimile machines, and related technology and anytechnology used to convey, transmit, or receive anykind of information (Access Board, 2004). Thesestandards provide criteria specific to various types oftechnologies, including software applications andoperating systems; web-based information orapplications; telecommunication products; video andmultimedia products; and self contained, closedproducts such as information kiosks, calculators, faxmachines, and desktop and portable computers. Thestandards provide technical specifications andperformance-based requirements, focusing on thefunctional capabilities of covered technologies.

Section 508 is “technology-centered” and focuses onwhether mainstream electronic and informationtechnology products meet the Section 508 standards,regardless of whether or not an agency has employeeswith disabilities or serves members of the public withdisabilities. The regulations implementing Section 504,the ADA, and Section 188 of WIA are “person-

DISTINCTIONS BETWEEN UNIVERSAL DESIGN & ASSISTIVE TECHNOLOGY

Renewable accessibility Consumable accessibility

Source: Bowe, 2000, p. 30.

Universal Design Assistive Technology

Responsibility of designers and developers Responsibility of user or user’s agent

Allows for serendipity Seldom is used in innovative ways

TABLE 2

Serves many people at once Serves one individual user at a time

Done while service or product is being developed Done after product is finished, or while service is being delivered

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centered” and focus on reasonable accommodation ofan individual’s disability in a particular setting.

As the Access Board’s Section 508 standards cannot—and do not pretend to—ensure that all electronic andinformation technology will be universally accessible toall people with disabilities, reasonable accommodationswill always be required in some instances. However, asagencies pay more attention to accessibility whenprocuring or developing their electronic andinformation technology, they will find it easier andeasier to provide reasonable accommodations whenrequired to do so. In some instances, people withdisabilities may not need accommodations at all, as theunderlying technology will be fully accessible to them.

Inaccessible technology interferes with a person’sability to obtain and use information quickly andeasily. Section 508 was enacted to eliminate barriers ininformation technology, to make available newopportunities for people with disabilities, and toencourage development of technologies that will helpachieve these goals. While Section 508 applies to thefederal government, a number of states have beenenacting laws or executive edicts imposing similarstandards on state and local agencies. And states arealso passing bills that require publishers to provideelectronic versions of their textbooks, just as Congresshas been considering similar legislation. In fact, therehad been so much activity on the electronic textbookfront that in 2002 and 2003, the US Department ofEducation convened a technical panel of accessibilityexperts and publishers to develop an appropriate set ofuniform standards to be used by all publishers. In thespring of 2004, the Department of Education endorsedthe panel’s recommendation regarding the use of theNational Instructional Materials Accessibility Standardas the preferred voluntary standardized file format formaking textbooks accessible to students withdisabilities. The Department funded a technicalassistance center, known as the NIMAS DevelopmentCenter, to facilitate the understanding of the standards,identify relevant new research and technologicaladvances, and explore the potential of free-marketdistribution models for accessible materials.

Program Access“Program accessibility” is another key concept for

agencies and programs, one that has importantimplication for serving people with disabilities. Underseveral laws, publicly funded entities are prohibitedfrom denying people with disabilities equal access toparticipate in programs and activities because facilitiesare not accessible. Programs in the workforcedevelopment system, including youth-servingprograms, need to operate their programs, services,and activities so they are accessible to and usable bypeople with disabilities.

Under the hierarchy of obligations created in WIA,reliance on programmatic accessibility is permissibleonly where a particular facility is not required tocomply with the Act’s architectural accessibilityrequirements (US Department of Labor, 2003). The Act’sarchitectural accessibility requirements relate toconstruction and design of facilities specifically and,like the provisions relating to programmaticaccessibility, apply to the program whether or not thatprogram actually serves or employ someone with adisability. Specific architectural standards are spelledout in state and local building codes as well as inguidance published by the Access Board. In addition,many states have developed their own tools forassisting the workforce development system inassessing compliance with architectural accessibilityissues.

The requirement of program accessibility means thatwhen viewed in its entirety, the program or activityprovided by the recipient must be readily accessible toqualified individuals with disabilities. The recipientmust ensure that participants with various physicaland mental disabilities will have access to the programor activity. This obligation to make the program oractivity accessible in advance exists independent of arequest for a particular accommodation by a specificindividual. Therefore, even if an individual with adisability requests an accommodation that wouldimpose an undue hardship on the recipient, therecipient still has an overall obligation to make theprogram or activity accessible (US Department of Labor,2003).

When attempting to achieve program access,innovation and creativity are essential and can includeany or all of the following: redesign of equipment;

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reassignment to accessible locations; use of aides;delivery of services at alternative accessible sites; use ofaccessible vehicles and technologies; alternatives toexisting facilities; and construction of new facilities.Effective access must be provided to ensure integrationof people with disabilities into the same programs,services, and activities as non-disabled persons (USDepartment of Labor, 2003).

Monitoring and enforcement of these types of issues,generally speaking, are the purview of the USDepartment of Labor’s Civil Rights Center. In 2003, theDepartment issued a WIA Section 188 DisabilityChecklist, a compliance assistance tool designed toensure nondiscrimination toward and equalopportunity for people with disabilities in theworkforce development system (US Department ofLabor, 2003). The Checklist identifies basic requirementsunder Section 188 of WIA, including portions of theregulations implementing Section 504 of theRehabilitation Act. In addition, the Section 188Checklist includes lists of questions for each element ofthe Methods of Administration (US Department of Labor,2003). A Methods of Administration is a document thateach Governor must put into place which describes theactions that the state will take to ensure that its WIATitle I financially assisted programs, activities, andrecipients are complying, and will continue to comply,with the non-discrimination and equal opportunityrequirements of WIA and its implementing regulations.The Methods of Administration are a set of formalprocedures used as an alternative dispute resolutionprocess before pursuing litigation.

Yet, there are still large gaps in guidance and usefulinstruments for assisting One-Stops and otheremployment-related service providers in their struggleto understand how to make program access work forpeople with disabilities, particularly those with hiddendisabilities.

When considering accessibility for people withdisabilities, it is important to review the entireprogram, service, and activity as well as the specificpolicies, procedures, facility, materials, equipment, andtechnology. Policymakers and program administratorscan employ the concept of universal design to ensurethat their programs, services, and activities are, in fact,

accessible to and useable by the widest range ofcitizens.

Univeral ServiceThe term “universal service” within what we nowknow as the workforce development system was usedoriginally in the 1930s to describe the free labor marketexchange activities—that is, making job matchesbetween job seekers and employers—provided by onlyone institution, the state Employment Service. Thesources of the funds for this free service are from adedicated portion of the federal and state unemploy-ment insurance tax. With passage of the WorkforceInvestment Act (WIA) in 1998, the universal serviceconcept was expanded and linked to federal generalrevenue job training programs based on the desire toestablish a more user-friendly, streamlined employ-ment and training system.

WIA created a dual set of tasks for the states. The firstrequires states to establish a state and local governancestructure charged with overseeing a large portion ofthe federal workforce development investment withinthe state, while the second requires states to developthe building blocks of a new workforce developmentservice delivery system. WIA categorizes certainemployment and training services to be providedthrough One-Stop Centers as “core services,”“intensive services,” and “training services.” One-StopCenters blend funds from a set of mandated partners,and those services that are free to all can be culled frommultiple funding streams. However, the EmploymentService continues to be the primary resource tapped toprovide the universal services. If insufficient fundsexist through the One-Stop Center, the latter two typesof services (intensive and training) are to be madeavailable first to people on public assistance programsand other low income individuals (Workforce InvestmentAct, 1998).

Core services, which are to be made available on auniversal basis to everyone at no cost, are usually self-directed, although staff assistance is available, and theconsumer decides which services to use and how touse them. Core services include the following, inaddition to others: basic outreach, intake, and interestassessment; job search and placement assistance; accessto a wide variety of labor market, training, and support

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service information; and assistance in establishingeligibility for public assistance programs. Any jobseeker, or anyone seeking to advance his or her career,can access information on job vacancies, career options,student financial aid, employment trends, job search,resume writing, and employer interviewing (WorkforceInvestment Act, 1998). Yet the concept of universalservice is continuing to evolve, and one can anticipatethat even more changes will emerge in the years tocome.

America’s workforce development system is nowdesigned to increase employment, retention, andearnings of people participating in employment-relatedactivities with a reliance on a seamless service deliverysystem through One-Stop Centers. The workforcedevelopment system is comprised of a broad array ofentities at the national, state, and local levels that existwith diverse responsibilities for planning, funding,administering, and operating programs to assist youthand adults with and without disabilities to obtaineducation, training, job placement, and supportservices. States are charged with the task of developinga comprehensive workforce development systemwithin their boundaries. An overarching strategyembedded in WIA is that a state’s workforcedevelopment system should organize information,products, and services based on the presumption thatindividuals are best positioned to make their ownchoices about their career goals. Thus, one of the firstlevels of responsibility of government is to provideinformation to the general public in appropriate waysso individuals are positioned to make informed choicesfor themselves. Before individuals can make decisions,however, access to the information and myriad ofchoices must be universally available. This is not aneasy charge that has been placed upon the states.

Universal Work Support ServicesIn 2003, the Center for Law and Social Policy (CLASP)conducted a study centered on issues related to theidentification of what quality universal work supportservices should include. The goal of the CLASP surveyof 33 One-Stop directors was to examine the level ofaccess to seven work support programs: EarnedIncome Tax Credit, subsidized child care, food stamps,publicly funded health insurance, cash assistance, childsupport, and transportation assistance). Essentially, the

study found that access to work supports varied byprogram, depending on the relationship to otherprograms, staff expertise, and leadership attitudes(Richer, Kubo, & Frank, 2003). More than its findings, theCLASP analysis offers valuable insight into how todefine levels of acceptable access to workforcedevelopment system programs and services.

CLASP defined access to the seven work supportprograms in a number of different ways—the provisionof information about programs, referral to otheragencies for assistance, and the acceptance of programapplications on-site. Methods of providing informationranged from producing comprehensive handouts,which caseworkers then discussed with customers, toposting flyers or brochures in waiting areas or resourcerooms to group orientations where programs areintroduced and discussed. Referrals ranged from“active,” in which a One-Stop staff member actuallymade an appointment at the appropriate agency for theconsumer, to “passive,” in which the consumer mighthave been given an address and phone number, if that,and was expected to follow up on his or her own. On-site application assistance allowed customers tocomplete and submit an application for a given worksupport while at the One-Stop, with the help of either aOne-Stop employee or a worker from the appropriateagency that handles the work support programs(Richer, Kubo, & Frank, 2003).

CLASP divided the One-Stops surveyed into threecategories—high, medium, and low—to describe thelevel of access to work supports offered. A One-Stopwas classified based on the provision of informationabout work supports, the type of referrals made, theavailability of on-site applications, and the inaccessi-bility of work supports. Work supports were found tobe inaccessible via the One-Stop when only writteninformation or a passive referral was available to thosecustomers who asked. In other words, a work supportwas determined to be inaccessible if nothing was doneto facilitate a customer accessing the program.

In its assessment, CLASP suggests that making worksupports accessible through One-Stops has to gobeyond simply supplying information about theprograms; it must rise to the level of providingassistance with applying for the work supports.

Under this view, the highest level of access was on-sitecompletion and submission of an application,accomplished with staff assistance. Another level ofaccess was the provision of an active referral: a referralfor the consumer to a specific agency that can help theconsumer apply for the desired work support,including specific instructions on applying, caseworkerassistance in making the appointment, and caseworkerfollow-up subsequent to the application.

Less vigorous methods of providing access includedhaving an application physically available on-site butrequiring the consumer to go elsewhere to apply, andproviding a passive referral, in which a consumer wasgiven information about which agency to go to in orderto pursue an application. Work supports wereconsidered inaccessible when there was no application,no assistance in completing an application, and noreferral, or when the referral was so passive it wasmeaningless (Richer, Kubo, & Frank, 2003).

Universal Design for LearningUniversal design for learning is an emerging conceptfor teaching, learning, assessment, and curriculumdevelopment that draws upon and extends theprinciples of universal design used in architecture andproduct design. Use of the concept of universal designhas begun recently in education and other servicedelivery contexts, which is of particular interest to theworkforce development system and particularly toyouth-serving organizations. Universal design forlearning (UDL), a relatively new theory alreadyembedded in the federal law governing specialeducation programs and services, extends key conceptsof universal design into the education environment.“The key to helping all students achieve is identifyingand removing barriers from our teaching methods andcurriculum materials,” explain key staff members at theCenter for Accessing Special Technologies, the leadingresearch and technical assistance center on universaldesign for learning. “The UDL framework proposesthat educators strive for three kinds of flexibility: torepresent information in multiple formats and media;to provide multiple pathways for students’ action andexpression; and, to provide multiple ways to engagestudents’ interest and motivation” (Rose & Meyer, 2002).

Essentially, this emerging educational theory extends

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the basic universal design concept of built-in flexibilityto educational curriculum and teaching methods withthe notion that it can help teachers meet standardswhile addressing the unique needs of every student byimproving learning. It encompasses UniversallyDesigned Instruction (UDI) as well as the concept ofUniversally Designed Curriculum (UDC) andUniversal Design in Assessment (UDA). Each of theseconcepts deals with the idea that education, in general,should be designed up front for access by all students,whether in terms of the curriculum, the instructionalstrategies, or the assessment. “Developing powerfultechnologies to overcome barriers must be balanced bydesigning environments with fewer barriers. Thelesson of ADA is that small affordances built ineverywhere, like curb cuts and ramps, are as critical foraccess as are assistive technologies like motorizedwheelchairs,” CAST Executive Director David Rosetold Congress in 2001. “We need to use the newtechnologies not only to overcome existing learningbarriers, but also to design learning environments withfewer barriers right from the start” (Assistive TechnologyAct projects, 2004).

The Individuals with Disabilities Education Act of 1997required that all students, regardless of their abilities,be given the opportunity to become involved with andprogress in the general curriculum. All students shouldhave access to what is being taught; however,providing access involves more than giving everystudent a book or a computer. Teachers have to ensurethat their students are challenged by the subject matter,regardless of their developmental level. The recentlyenacted Individuals with Disabilities EducationImprovement Act of 2004 addresses universal designfor learning in five key areas: standards, studentassessment, technology, curricula, and instructionalmaterials (Individuals with Disabilities EducationImprovement Act of 2004).

The Council for Exceptional Children has put forththe following definition for universal design ofinstruction:

• In terms of learning, universal design means thedesign of instructional materials and activities thatmake the learning goals achievable by individualswith wide differences in their abilities to see, hear,

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hear, move, read, write, attend, organize, focus, engage,and remember. For example, text in standard printformat presents a barrier for students who are dyslexicand for students with English as a second language,and is inaccessible for blind students. The same textwhen delivered in a digital format offers many options.It can be read aloud by a computer or screen reader,printed on a Braille printer, and presented in spoken orwritten translation or with highlighted main points andorganizational supports.

Educators have traditionally adapted books and teststo accommodate students’ diverse learning needs togive them an opportunity to progress in content areas.The usual accommodations are Braille and recordedtexts for the visually impaired student, captionedmaterials for the hearing-impaired, and customizedsupplementary materials to address cognitivedisabilities. These accommodations are usually addedto the standard curriculum much like adding awheelchair ramp to a building to provide access.Architectural accommodations added later aresometimes awkward and expensive; likewise,curriculum adaptations can be time consuming todesign and difficult to implement in a classroom ofdiverse learners. It is much more efficient toincorporate student access by considering the range ofuser abilities in the beginning stage of curriculumdesign. Designing with accessibility of all possibleusers in mind is the underlying principle of universaldesign.

CAST has developed three principles of universaldesign for learning formed to minimize barriers andmaximize learning through flexibility. The overarchingprinciples are the following:

• To support recognition learning, provide multiple,flexible methods of presentation;

• To support strategic learning, provide multiple, flexi-ble methods of expression and apprenticeship; and,

• To support affective learning, provide multiple, flexi-ble options for engagement (Rose & Meyer, 2002).

Universal design principles for learning can be appliedto lectures, classroom discussions, group work,handouts, web-based instruction, labs, field work, andother academic activities and materials. As CAST

speak, move, read, write, understand English, attend,organize, engage, and remember. Universal designfor learning is achieved by means of flexible curricu-lar materials and activities that provide alternativesfor students with differing abilities. These alterna-tives are built into the instructional design and oper-ating systems of educational materials – they are notadded on after-the fact. (Center for ExceptionalChildren, n.d.)

According to the Center for Accessing SpecialTechnology (CAST), universal design for learningshifts long-held assumptions about teaching andlearning in four fundamental ways:

• Students with disabilities are on a continuum oflearner differences rather than constituting a separatecategory.

• Teachers should adjust for learner differences in allstudents, not just those with disabilities.

• Curriculum materials should not be dependent on asingle textbook; rather they should be varied anddiverse, including digital and online resources.

• Curricula should be made flexible instead of remedi-ating students to learn from an inflexible curriculum(Center for Accessing Special Technology, n.d.).

In education, the traditional teaching approach hasbeen one in which instruction is delivered to suit thecomfort of the teacher without much understanding ofhow to accommodate individual learning needs.Universal design for learning challenges this approachand calls on all participants to reconsider who shouldbe responsible for ensuring accessibility. It askseducators to look at courses, textbooks, schedules,delivery styles, and other aspects of education toconsider the many possible methods of instruction fora diverse set of learning approaches. Accounting fordifferent learning needs by planning in advance canmake instruction available for more students, at lowercost, and reduces the need for after-the-fact steps suchas interpreting and Brailing or tape-recording ofprinted material.

Clearly, no two students learn exactly the same way.Rather, the range of performance and ability ofstudents varies greatly in terms of their ability to see,

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explains, these principles give “each studentmeaningful access to the curriculum by assuring accessto the environment as well as multiple means ofrepresentation, expression, and engagement” (Center forAccessing Special Technology, n.d.). Youth-servingorganizations in the workforce development systemcan learn from, and help expand the practices ofuniversal design for learning.

Current PracticesAt this time, there have been no comprehensiveevaluations of how the workforce development systemis or is not implementing the various meanings ofuniversal access, whether in the context of employmentservices generically or from a disability perspective.Congress does, however, continue to hear anecdotalevidence from disability community advocates thatpeople with disabilities are not being served in One-Stop centers because they are not accessible in one way or another.

The Government Accountability Office (GAO) recentlypublished a report noting that “little is known, andquestions have been raised, about how well this system(workforce development system) is working forpersons with disabilities.” The GAO recommendedthat the US Department of Labor develop andimplement a “long-term plan for ensuring that theOne-Stops comply with the comprehensive accessrequirements” of WIA (Government Accountability Office,2005).

There are, however, a few recent studies and surveys ofaccessibility issues in the workforce developmentsystem that shed some light on current policies andpractices around universal access, one by the Center onthe Study and Advancement of Disability Policy(CSADP) and another by an association representingstate Assistive Technology projects. Additionalperspectives can be garnered from the first year’s casestudy work completed by the National Collaborativeon Workforce and Disability for Youth (NCWD/Youth).These viewpoints highlight the challenges theworkforce development system faces in trying toachieve the comprehensive definition of universalaccess proposed herein.

The work of CSADP examined activities of six selected

states against the back drop of the US Department ofLabor’s WIA Section 188 Disability Checklist.Originally, CSADP planned to develop a baseline forassessing the nature and extent of changes over time tothe policies and procedures described and/or attachedto WIA Methods of Administration developed by six“leading edge” states regarding the implementation ofSection 188 for people with disabilities. The six statesexamined were Maryland, Minnesota, New Jersey,New York, Texas, and Washington. However, asCSADP’s research evolved, it also identified state-based examples of policies, procedures, and otherrecommended steps included in state Methods ofAdministration that Local Workforce Investment Areagrant recipients can take to ensure that people withdisabilities have equal access to WIA Title I financiallyassisted programs and activities.

While CSADP’s examined nondiscrimination andequal opportunity for people with disabilities, thespecific state practices identified in the Methods ofAdministration are helpful for understanding whattypes of policies and practices exist and what work isyet to be done, including development of useful toolsand products for the workforce development system.

1) Universal Access: The Department of Labor’sSection 188 regulations specify that states must takeappropriate steps to ensure that they are providinguniversal access to WIA Title I financially assistedprograms and activities. These steps must involvereasonable efforts—including advertisement,recruitment, outreach, and targeting—to includeparticipation of people with disabilities in theprograms and activities.

One of the major findings of CSADP’s analysisconcluded that because most of the provisions in theregulations spell out general responsibilities relating topeople with disabilities, there were “significantvariations among the States in the nature and extent,i.e., degree of comprehensiveness of State policies.” Forexample, with respect to policies concerning universalaccess, there was “significant variation in what stepswere considered ‘appropriate’ and what efforts were‘reasonable’ to ensure that universal access includesaccess for persons with disabilities. Some Statesincluded specific steps such as making contact with the

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Governor’s Committee/Office on individuals withdisabilities, State vocational rehabilitation and otherdisability specific agencies such as MentalRetardation/Developmental Disabilities (MR/DD) andmental health, and contacting special educationteachers. Additional steps included designation of oneperson to serve as a liaison with disability groups.Other States included generic examples but did notinclude specific examples applicable to persons withdisabilities” (Silverstein, 2003).

2) Nondiscrimination on the Basis of Disability: TheSection 188 regulations also require recipients of WIAfunds to prohibit discrimination in the registration forand the provision of aid, benefits, services, or training,including core, intensive, training, and supportservices, on the basis of disability. The Section 188Checklist summarizes the legal requirements of Section188 and provides examples of what is considereddiscrimination on the basis of a disability, based in parton long-standing interpretations of the ADA andrelated disability rights legislation. By way of example,here are a few of those specifications, highlightedbecause they are directly relevant to a discussionaround universal access in the workforce developmentsystem:

• All activities are to be offered to people with disabili-ties in the most integrated setting appropriate, anddifferent, segregated, or separate aid, benefits, servic-es, or training may not be provided to people withdisabilities unless necessary to assure that the aid,benefit, service, or training is as effective as that provided to others;

• In determining the site or location of a facility, therecipient must not make selections that have a discriminatory effect;

• A recipient must not administer a licensing or certification program in a discriminatory manner;

• The recipient must not impose or apply eligibility criteria that screen out or tend to screen out an indi-vidual with a disability or class of individuals withdisabilities unless such criteria can be shown to benecessary for the provision of the aid, benefit, service,training, program, or activity being offered;

• An individual with a disability is not required to

accept an accommodation, aid, benefit, service, training, or opportunity that such individual choosesnot to accept.

CSADP found that the states “vary significantly in howthey restate the general prohibitions againstdiscrimination on the basis of disability.” While somestates “simply prohibit discrimination on the basis ofdisability, others incorporate by reference the federalregulations, and others restate some but not all of thespecific forms of discrimination listed in the federalregulations.” In addressing the issue of site selection,for example, Minnesota identifies the availability ofpublic transportation as one of the key criteria forlocating One-Stop Centers. Both Minnesota andWashington have issued policies regarding testing, andthe need to make modifications and accommodations(Silverstein, 2003).

3) Reasonable Accommodation and Modifications: TheSection 188 regulations require that the recipients ofWIA funds must provide reasonable accommodationsregarding registration for and the provision of aid,benefits, services, or training, including core, intensive,training, and support services, to qualified individualswith disabilities unless providing the accommodationwould cause undue hardship. In addition, theregulations require that reasonable modifications bemade to policies, practices, and procedures unlessdoing so would fundamentally alter the nature of theservice, program, or activity.

CSADP found that all the states were committed toproviding reasonable accommodations to customersand employees with disabilities. Some states includedcomprehensive policies and procedures implementingthe requirements, including overall policy, definitions,responsibilities of clients, responsibilities of programadministrators, confidentiality, complaint resolution,and resources. Other states simply restated the generalobligation without any details. Maryland has “adoptedthe ‘Never Say No’ philosophy whereby ‘no’ is ananswer of last resort—after all reasonable options havebeen explored by the individuals making and receivingthe request” for reasonable accommodations. Marylandoffers related training on a regular basis. Washingtonstated its commitment and gave concrete examples ofreasonable accommodations offered, including

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qualified sign language interpreters, readers, auxiliaryaids, and alternate formats.

Some states have issued specific policy directivesinstructing local workforce investment boards toinclude in their local plan a description of their plan toprovide reasonable accommodations to qualifiedindividuals with disabilities, while other states simplyinclude policies in their monitoring instruments.

However, CSADP found that “most of the States withspecific policies regarding reasonable accommodation/modifications did not have specific policies applicableto the One-Stop service delivery system; rather theyincluded in the MOAs policies generally applicable toall of the customers of the State agency’s programs andactivities” (Silverstein, 2003).

4) Most Integrated Setting: The Section 188regulations also specify that the recipients of WIAfunds must administer their programs and activities inthe most integrated setting appropriate to the needs ofqualified individuals with disabilities. In addition, therecipients may not provide different, segregated, orseparate aid, benefits, services, or training to peoplewith disabilities unless necessary to assure that the aid,benefit, service, or training is as effective as thoseprovided to others. There are two additional relatedrequirements: 1) the separate aid, benefits, services, ortraining must be in fact as effective as that provided topersons without disabilities; and 2) the choice as towhether a particular person with a disability willparticipate in the segregated or the “regular” programmust be in the hands of the person with a disability.

Several states simply restate the general obligation toensure that people with disabilities participate in themost integrated setting appropriate, while other statessupplement this general statement with specifics. Forexample, New Jersey states that “It is clear thatautomatic referral to a program/agency that isdesigned solely for individuals with disabilities may bediscriminatory and will not suffice as a reasonableaccommodation if the customer desires to participate in‘mainstream’ services, activities, training, benefits, oraids” (Silverstein, 2003).

5) Obligation to Communicate Effectively: The Section188 regulations also require that recipients of WIA

funds take steps to ensure that communications withpeople with disabilities are as effective ascommunications with others. The obligation tocommunicate effectively with people with disabilitiesrequires both generalized action in advance andspecific steps to meet the individual needs of aparticular person with a disability. Recipients mustfurnish appropriate auxiliary aids and services wherenecessary to afford people with disabilities an equalopportunity to participate in, and enjoy the benefits of,the WIA Title I financially assisted program or activity.It is suggested that recipients give primaryconsideration to the requests of the person with adisability when determining what type of auxiliary aidor service is appropriate. Where a recipientcommunicates by telephone with beneficiaries andothers, the recipient must use telecommunicationdevices for individuals with hearing impairments(TDDs or TTYs) or equally effective communicationsystems, such as telephone relay services. And,recipients must ensure that interested individuals,including individuals with visual and hearingimpairments, can obtain information as to the existenceor location of accessible services, activities, andfacilities, including the provision of appropriatesignage at the primary entrances to its inaccessiblefacilities.

CSADP found that all six states have issued generalpolicy guides pertaining to effective communication forall categories of people with disabilities, “although thedegree of specificity included in the policy directivesvaries from a simple restatement of the requirementsspecified in the Federal regulations to in depthexplanations of how to provide effectivecommunication” with people with disabilities,including specific lists of auxiliary aids and servicesand assistive technology devices available at One-Stopcenters. Minnesota has developed extensive policydirectives, guides, and monitoring instrumentsaddressing effective communication. For example, aguide has been distributed describing how tocommunicate with people with all types of disabilities.Minnesota requires its One-Stop Centers to haveassistive technology available and has purchasedseveral items such as VCRs and TV monitors withclosed-captioning capability, screen enlargers, anddocument readers. New York lists examples of

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auxiliary aids and services in their monitoringinstrument that include qualified interpreters, assistivelistening headsets, closed and open captioning onvideos, telecommunication devices for the deaf,computers that allow voice input and output, readers,taped texts, Braille materials, videotext displays, andtranscription services. Through its monitoringinstrument, New York goes so far as to ask whetherOne-Stop staff are familiar with communicationprocedures to assist blind and visually impairedindividuals, such as the importance of verbalizingdirections, the need to initiate introductions tocustomers who are visually impaired, the need forverbally communicating important information that isnot readily apparent to a person who is visuallyimpaired, awareness of alternatives to normal-sizeprint materials available in their center, and anunderstanding of how to use signature guides(Silverstein, 2003).

6) Programmatic and Architectural Accessibility: With the incorporation of regulations implementingSection 504 of the Rehabilitation Act, the Section 188regulations specify that recipients of WIA funds mustoperate each program or activity so that the programor activity, when viewed in its entirety, is readilyaccessible to qualified individuals with disabilities.They are required to comply with this obligationthrough such means as redesign of equipment,reassignment of classes or other services to accessiblebuildings, assignment of aides to beneficiaries, homevisits, delivery of services at alternative accessible sites,alteration of existing facilities and construction of newfacilities in conformance with standards for newconstruction, or any other method that results inmaking the program or activity accessible to peoplewith disabilities. In choosing among available methodsto ensure access, recipients must give priority to thosemethods that offer programs and activities to peoplewith disabilities in the most integrated settingappropriate. As discussed previously, however,recipients may comply with the programmaticaccessibility requirements only where their facilities arenot required to comply with architectural accessibilityrequirements, discussed below.

Under the architectural accessibility requirements, eachnew facility or part of a facility constructed by, on

behalf of, or for the use of a recipient must be designedand constructed in such a manner that the facility orpart of the facility is readily accessible to and usable bypeople with disabilities. Each facility or part of afacility that is altered by, on behalf of, or for the use of arecipient in a manner that affects or could affect theusability of the facility or part of the facility must bealtered in such a manner that the altered portion of thefacility is readily accessible to and usable by peoplewith disabilities. The design, construction, or alterationof facilities must meet the most current UniformFacility Accessibility Standards (UFAS) for physicalaccessibility prescribed by the General ServicesAdministration under the Architectural Barriers Act orthe recipient may adopt alternative standards when itis clearly evident that equivalent or greater access tothe facility or part of the facility is thereby provided.Acceptable alternative standards include both ADAAGand the new ADA-ABA Accessibility Guidelinespublished by the Access Board in July 2004.

CSADP found that all six states have developed achecklist or distributed checklists developed by federalagencies to ensure physical access to services providedin existing facilities and new construction andalterations. Also, states have adopted policies assertingand directing programmatic access for WIA fundingrecipients (Silverstein, 2003).

Another instructive, albeit limited, study, which shedslight on access-related activities in One-Stops, comesfrom the first year report of the NCWD/Youth casestudy research (Academy for Educational Development,2003). In an attempt to have practice inform policy, theDepartment of Labor’s Office of Disability EmploymentPolicy funded NCWD/Youth to conduct a four-yearfield study to document the actual challenges faced andstrategies employed by states and local communities inserving youth with disabilities within the workforcedevelopment system. A comparable study is beingconducted to look at services being provided to adultswith disabilities under WIA by the Collaborative’s sistertechnical assistance center, the National Center onWorkforce and Disability/Adults (NCWD/Adult). Thesix local sites selected for the youth case study workwere Tucson, Pima County, Arizona; Albany, DoughertyCounty, Georgia; Waterloo, Black Hawk County, Iowa;Syracuse, Onondaga County, New York; Providence,

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Providence County, Rhode Island; and, Bellingham,Whatcom County, Washington.

“Most sites have made a concerted effort to guaranteephysical access to persons with disabilities and toensure there are assistive technology devices availablefor their use,” the NCWD/Youth reports. “In mostinstances they have also trained some staff on how touse the equipment” (Academy for EducationalDevelopment, 2003). Many states and localities havetaken advantage of funding from the Department ofLabor’s Employment and Training Administration,under the Work Incentive Grants, as well as used someof their own WIA discretionary funds to make accessmodifications to facilities and purchase adaptive andaccessible technologies.

The following two local sites stood out in terms of theNCWD/Youth’s assessment of accessibility from adisability perspective:

When the site in Albany, GA was dedicated as a One-Stop, there was a “career conversion” to make thebuilding and programs accessible. Accessibility featuresput into place included: work stations at accessible height,large monitor, voice sound/tones for hearing impaired, aflatbed scanner, a trackball, a visual machine to makeforms larger, a foreign language machine (translates toFrench, Spanish, and German), and a TTD relaymachine. Visible signage (words and pictures) lists theassistive technology in the One-Stop. Private rooms areavailable for confidential discussions or as a quiet workspace. Customers are routinely offered accommodationsand assistance, staff is available to assist in completingapplications or offer materials in alternative formats.There is also dedicated staff available in the resourcecenter and a VR assistant is on site 20 hours a week.

The Syracuse One-Stop facility is “user-friendly” forindividuals with disabilities. “The One-Stop staff doesn’tsend youth with disabilities directly to VESID(Vocational and Educational Services for Individuals withDisabilities). Frontline workers are very aware of how towork with people with disabilities who come in the door.”From the first time a customer with a disability comesthrough the One-Stop’s doors, all staff are comfortableand competent to work with that person, withoutautomatically referring them to “specialists.” Electronic

access to the One-Stop and its services makes the site andinformation more accessible to customers with disabilitieswho are computer savvy. This new system, especiallythrough Internet technology, brings access andinformation into the center city neighborhoods ofSyracuse as well as to the county boundaries (Academyfor Educational Development, 2003).

The NCWD/Youth report notes that “simply makingsites accessible and providing the correct assistivetechnology isn’t enough to ensure that persons withdisabilities are being adequately served” (Academy forEducational Development, 2003). The report recommendsthe establishment of accessibility teams and intensivestaff training around access and assistive technologyissues. As one site put it, “universal access is imbeddedin the way we do business here. The One-Stop does anexcellent job of ensuring that appropriate supports andaccommodations are provided. If staff encounters anew situation that they do not feel they can handleadequately, they will go immediately to one of ourpartners to get assistance. When youth requireadditional services, a youth counselor sits down withthat individual and his/her advocate and together theymap out a strategy for accessing those services”(Academy for Educational Development, 2003).

A third collection of disability-related accessibilityinformation comes from a survey conducted by aloosely knit consortium of state Assistive TechnologyAct projects. In response to a request from Congress, inthe spring of 2004 19 state projects answered a surveyabout disability-related accessibility issues in One-Stops. The following list includes a few of thehighlights:

[In Arizona, the One-Stops reviewed] had basicknowledge of ADAAG (Americans with Disabilities ActAccessibility Guidelines) and Section 508 requirements.Out of the three that were audited only one appeared to bereasonably accessible.

In Illinois, with the assistance of WIG funds, 44comprehensive One-Stops were provided a set of assistivetechnology devices. Unfortunately, the audits revealedthat many of the One-Stops keep their devices boxed andnot set up in the resource room. A few of the One-Stopsthat did have their assistive technology devices set up

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placed a sign on it that read “Disabled Use Only.” Onlya few One-Stops has purchased assistive technologydevices on their own and certainly none of the One-Stopshad anywhere near a complete array of access devices thatwould address computer input/output, telephony, printaccess and aural communication needs of individuals withphysical and sensory disabilities.

In Louisiana, ADAAG architectural access standardswere used and about half the centers were in substantivecompliance and the remaining facilities were significantlyout of compliance. (The status of the One-Stop CareerCenters in the southern portion of the state is unknownbut assumed to be a similar ratio to those audited.) ADAgeneral program access guidelines were used during theaudit. None of the facilities had anywhere near a completearray of access devices that would address computerinput/output, telephony, print access, and auralcommunication needs of individuals with physical andsensory disabilities.

In Missouri, of 38 full service One-Stop Career Centers,23 were audited for architectural and programmaticaccessibility…ADAAG architectural access standardswere used and 19 centers were in substantive complianceand the remaining 4 facilities were significantly out ofcompliance. (The status of the 15 not audited is unknownbut assumed to be a similar ratio to thoseaudited.)…ADA general program access guidelines wereused during the audit and what became apparent was theneed for specific access standards for computers andtelephony which were developed later. None of thefacilities had anywhere near a complete array of accessdevices that would address computer input/output,telephony, print access and aural communication needs ofindividuals with physical and sensory disabilities. One ofthe 23 centers had a screen magnification program, onehad a Closed Circuit Television (CCTV) and 5 hadTTY’s. The status of the 15 not audited is unknown butassumed to be similar to those audited with limited tonon-existent assistive technology available.

In Nebraska, the Assistive Technology Project (ATP)utilized the Facilities Checklist and Service AccessibilityChecklist developed by the U.S. Department of Labor’sOne-Stop Disability Initiative as published in the Accessfor All: A Resource Manual for Meeting the Needs ofOne-Stop Customers with Disabilities. ATP’s

audits/reviews resulted in a finding that 5 of 14 locationswere substantially in compliance with the checklists withonly minor fine-tuning needed; 8 locations had significantdesign barriers, and 1 location had very significantarchitectural barriers. These barriers varied from simple,easily corrected issues such as placement of resource roomfurniture, use of swing clear hinges, and best location fordesignated parking. More costly solutions included needfor automatic door opener systems and restroommodifications. In 4 locations, the One-Stop either needs toremodel their space or are in the planning stages to find anew location (AT Project Audits, 2004).

There are many important issues raised in thisexamination of current practices in the workforcedevelopment system. Additionally, technical assistancetools are needed to assess programmatic access,universal access, and universal services in One-Stopcenters. Many states beyond the six examined byCSADP have created excellent architectural designchecklists for assuring architectural accessibility tofacilities, such as Georgia, California, and Colorado.Colorado has even developed a checklist to surveyOne-Stop staff competencies around accessibilityrequirements. However, there appears to be asignificant void of useful tools to assist WIA programoperators in conducting self-assessments of theirprograms in their entirety—not to mention materials toassist them in achieving the definition of universalaccess promoted herein.

ConclusionA strategy for moving the workforce developmentsystem toward a more comprehensive definition ofuniversal access is in order. This paper advocates theadoption of a definition of universal access that buildsupon the elements of universal service and universalaccess currently used in the employment and trainingarena, while incorporating the concepts of architecturalaccessibility, program accessibility, and universaldesign from the disability policy arena. Specifically, inthis paper NCWD/Youth proposes defining universalaccess as “the design of environments, products andcommunication as well as the delivery of programs,services and activities to be useable by all youth andadults, to the greatest extent possible withoutadaptation or specialized design.”

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Such a monumental change in definition will haveenormous implications for policymakers andpractitioners alike. Accordingly, implementing thisdefinition will require thoughtful deliberation. EvenRon Mace recognized that the term “universal” is notideal because it could be interpreted to promise animpossible standard.

Federal policymakers will need to come to agreementon common terminology, standards, andmeasurements. Useful tools and instruments will needto be developed to assist youth and adult workforceprogram practitioners to conduct self-assessments, andoperationalize, implement, and measure their successin achieving universal access. Program administratorswill need clear mechanisms for measuring activeversus passive application of this definition ofuniversal access. Staff competencies will need to beestablished and a training agenda will be necessary.

Although it will require substantial work to achieve, atthe end of the day if the proposed definition isadopted, the workforce development system will be ina much better position to meet the needs of all of itscustomers, both with and without disabilities.

NCWD/Youth, in partnership with its sponsoringagency the Office of Disability Employment Policy atthe US Department of Labor, is committed tofacilitating agreements around, and a betterunderstanding of, universal access throughout theworkforce development system through materialsdevelopment and dissemination as well as ongoingtraining and technical assistance activities. To that end,NCWD/Youth intends to convene a panel of expertsacross disciplines to address these findings andconclusions as well as to assist in the development andvalidation of materials on these subjects.

Source: Center for Universal Design, n.d.

APPENDIX A

KEY CONCEPTS OF UNIVERSAL DESIGNPrinciples, Definitions, and Guidelines

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4

5

6

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2

EQUITABLE USE: Design is useful and marketable to people with diverse abilities.

Guidelines:a) Provide the same means of use for all users: identical whenever possible and equivalent when not;b) Avoid segregating or stigmatizing any users;c) Make provisions for privacy, security, and safety equally available to all users;d) Make design appealing to all users.

FLEXIBILITY IN USE: Design accommodates a wide range of individual preferences and abilities.

Guidelines:a) Provide choices in methods of use;b) Accommodate right-or left-handed access and use;c) Facilitate the user’s accuracy and precision;d) Provide adaptability to the user’s pace.

SIMPLE & INTUITIVE USE: Use of design is easy to understand, regardless of the user’s experience, knowledge,language skills, or current concentration level.

Guidelines:a) Eliminate unnecessary complexity;b) Be consistent with user expectations and intuition;c) Accommodate a wide range of literacy and language skills;d) Arrange information consistent with its importance;e) Provide effective prompting and feedback during and after task completion.

PERCEPTIBLE INFORMATION: Design communicates necessary information effectively to the user, regardless of ambient conditions or the user’s sensory abilities.

Guidelines:a) Use different modes (pictorial, verbal, tactile) for redundant presentation of essential information;b) Maximize “legibility” of essential information;c) Differentiate elements in ways that can be described (i.e., make it easy to give instructions or directions);d) Provide compatibility with a variety of techniques or devices used by people with sensory limitations.

TOLERANCE FOR ERROR: Design minimizes hazards and adverse consequences of accidental or unintended actions.

Guidelines:a) Arrange elements to minimize hazards and errors: most-used elements most accessible;

hazardous elements eliminated, isolated, or shielded;b) Provide warnings of hazards and errors;c) Provide fail-safe features;d) Discourage unconscious action in tasks that require vigilance.

LOW PHYSICAL EFFORT: Design can be used efficiently and comfortably and with a minimum of fatigue.

Guidelines:a) Allow user to maintain a neutral body position;b) Use reasonable operating forces;c) Minimize repetitive actions;d) Minimize sustained physical effort.

SIZE AND SPACE FOR APPROACH AND USE: Appropriate size and space is provided for approach, reach,manipulation, and use regardless of user’s body size, posture, or mobility.

Guidelines:a) Provide a clear line of sight to important elements for any seated or standing user;b) Make reach to all components comfortable for any seated or standing user;c) Accommodate variations in hand and grip size;d) Provide adequate space for the use of assistive devices or personal assistance.

Academy for Educational Development. (2003,September). How youth with disabilities are servedthrough the workforce development system: Case studyresearch across six sites (Year 1). Washington DC:Author.

Access Board. (2004, July). Americans with DisabilitiesAct and Architectural Barriers Act accessibility guide-lines for buildings and facilities. Washington, DC:Author.

Access Board. (2001). Section 508 Guidance. Washington,DC: Author. Retrieved May 27, 2005from<http://www.access-board.gov/508.htm>.

Access for all: A resource manual for meeting the needs ofOne-Stop customers with disabilities. (2002). Boston,MA: National Center on Workforce &Disability/Adults.

Americans with Disabilities Act. (1990). Public Law101-336.

Assistive Technology Act. (2004). Public Law 105-394.

Assistive Technology Act projects: Survey of state ATprograms on the status of accessibility of informa-tion technology, telecommunications, and build-ings used by One-Stop Employment Centers. (2004,Spring). Washington, DC Assistive Technology ActProjects.

Barnow, B. S. & King, C. T. (2003,July). The WorkforceInvestment Act in eight states: Overview of findingsfrom a field network study. Albany, NY: RockefellerInstitute of Government.

Bowe, F. G. (2000). Universal design in education:Teaching nontraditional students. Westport, CT:Bergin & Garvey.

Burgstahler, S. (2005). Universal design of instruction.Seattle, WA. University of Washington DOIT.

Center for Accessing Special Technologies. (n.d.). Webpage. <http://www.cast.org>.

Council for Exceptional Children. (n.d.). Web page.<http://www.cec.sped.org/osep/udesign>.

Center for Universal Design. (n.d.). Web page.<http://www.design.ncsu.edu>.

Center on Disability Studies. (2003, November). Amodel for accessibility. Manual. Manoa, HI:University of Hawaii.

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