Good day, ladies and gentlemen and welcome to the Ins and Outs of conducting a self-evaluation for local government conference call. At this time, all participants are on a listen-only mode. They only will conduct the question and answer session and instruction will follow at that time. If anyone should require operator assistance during the conference, please press Star and then 0 on your touchtone telephone. As a reminder, this conference call is being recorded. I would now like to turn the call over to your host, Miss Robin Jones. Please go ahead.
Well, good afternoon or good morning to everyone and wherever you maybe connecting with us today. My name is Robin Jones and I am the Director of the Great Lakes ADA Center which is one of the ten federally funded regional technical assistance centers on the Americans with Disabilities Act and a member of the ADA National Network. Today''s program is being brought to you as part of the collaborative effort of the ADA National Network to bring training and technical assistance to people in communities on topics that are relevant to you. In a few minutes--moments I will be introducing our speakers for today''s session. But I just I want to cover a few of the technical issues before we start today. Please know that this session is being recorded and a transcript--written transcript as well as the recording of today''s session will be made available on our website at www.ada-audio.org under the ADA audio conference series section archive. That should be up between approximately five business days after we''ve been able to edit the transcript and get it posted. So if you want to review something or you I want to refer another colleague or somebody to it, you can do it through that particular process. We have individuals joining us today using a mode of--different modes of technology. We have individuals on the telephone. We also have individuals who are using streaming audio on the internet and we have individuals who are using real time captioning streamed on the internet. During the question and answer period, the operator will be giving instructions to those that are on the telephone on how to ask question. Individuals who are using streaming audio and/or captioning would use the instructions that were provided to then in regards to how to go about, providing in advance into how to submit questions and we will be addressing all of your questions as much as time permit us to do so today. It is rather timely. I want to say that we are addressing this particular topic today as it is March 15th of 2011 which is the effective date for the Title II and Title III Regulations that were issued on September 15th of 2010. So it''s a--with that in mind that we will be going forward today talking about, what really does a Title II entity need to think about in regards to ensuring that they are not only compliant with the regulations that were effective in January 26th of 1992 but also what does that mean for me now that we have some revisions to the ADA, the first major revision to the ADA since implementation about 18 years ago. So I think that I didn''t really think about that when we plan this session for this month, but it is serendipitous that that''s actually what occurred. We are very honor and privilege today to have with us two highly qualified speakers to address this topic with us. First, I want you to introduce Irene Bowen. Irene Bowen is the owner and operator of a consulting company known as ADA One. She is a nationally recognized consultant, trainer, and speaker. And--But before starting her firm in 2009, she was the Deputy Chief of the Disability Right Section at the Department of Justice. In that role, she oversaw enforcement of the ADA and was actively involved in the development of the original ADA accessibility guidelines as well as the Department of Justice''s Title II and Title III Regulations and the revision to them. So, Irene lived with these regulations close to her heart, in her briefcase, and in her desk and piles and piles of paper for many, many years before she retired and was happy to see them actually come into print in 2010. Many of her clients now in the private sector include local governments, colleges and universities, places of public accommodation as well as federal agency. She works closely in teams with architecture firm called LCM Architects and other entities to assist them in developing cost-effective approaches to the compliance. She recently has to her credits an ADA guides for nonprofit that was issued and commissions by the Chicago Community Trusts and it was issued in January of 2011. Prior to all of these things with the Department of Justice and her current ventures, she was the Deputy General Counsel of the US Access Board, and co-founded the National center for Law and Deafness. She is an attorney and received her degree from the George Washington University Law School. Our second presenter today is Sally Conway. Sally is with US Department of Justice Civil Rights Division and she is currently serving as the deputy--Deputy Chief in that particular position which is recent--a promotion for her. She is assigned to the District Rights section which is responsible for providing technical assistance about the requirements of Title II and Title III of the ADA and investigations and we''re necessary litigating Title I, II, and III complaints and certifying state and local building codes. Sally''s background is she has a bachelor''s and master''s degree in different field. She''s work in disability rights and civil rights for more than 20 years. She has conducted training sessions, workshops, and presentations on the ADA in a multitude of areas far and wide across the country and beyond and works closely with both public and private sectors related to those issues. She''s responsible for the department''s wide-reaching ADA Technical Assistance Program and that includes the Business Connection program, the development of new technical assistance materials, the ADA Information Line that many of you may be familiar with, and they--that line and no services reach many, many people all over the place. She''s also involved with ADA Mediation Program which is an option within the Department of Justice for businesses, state and local governments, and people with disabilities to use as an efficient, effective and voluntary alternative to resolving complaints under the ADA. She serves as a Congressional Liaison for ADA and other disability related manners--matters. Prior to her life with the Department of Justice she was the Program Director for Granite State Independent Living in New Hampshire, and she has also had experienced working as an investigator for the New Hampshire Commission on Civil Rights. So she has a vast background and experienced in those area. And I think what you''ll hear from both of our presenters today is some really common sense, common approaches to this particular issue based on their vast experienced and the work that they''ve done with many, many other entities. So without further ado and to make sure we get full use of our presenters and opportunity for access to all of you to asks questions today, I''m going to turn it over to Sally and everyone should have the handout materials and be able to follow us along today as well. So, go ahead. I''m sorry, not Sally. I''m handing it over to Irene. Don''t I want to throw off there the two of you. So I''m going to go ahead and hand it off at this time to Irene. Go ahead Irene.
Thanks, Robin and happy Ides of March to everyone. As Robin mentioned sort of the headline I guess today is that the new requirements are in effect under the Title II and Title III regulations. I''m thrilled to be here with both Robin and Sally and with all of you to sort of analyze what does this mean for all of us and we''re going to start on slide 2 with legal mumbo jumbo. I no longer give legal advice and we want to make sure that you know that this presentation is not intended to give you legal advice, but general information can be applied to specific PAT patterns and if you do need legal advice, there''re plenty of people who are willing and able to give that. And on to slide number 3, as a Robin mentioned this is really timely because the regulations become effective today although the new standards, 2010 standards, don''t take effect for purposes of alteration and new construction until next year on the Ides of March. But in general as you know, the provisions about policy changes are in effect. Now keep in mind that most of the provisions of the regulation from 1991 are still effect. Not all of them have been change although of course we do have new standard and changes to certain sections of the 1991 regulation. And I know that you all are probably familiar with the basic requirements--the procedural requirements but we''re going to review those real quickly starting with slide 3 before we get to the specifics that--of the changes that has been brought about. And Sally is going to make sure we all understand those very clearly before the hour and a half is over. But you''re probably wondering things like is a new self-evaluation required as a new transition plan required? If it''s not, should state and local governments do them anyway? How do they go about it? And how do the new regulations affect the process? So those are the questions that we hope to answer today, starting with the basic than the specifics of the DOJ provisions and then the practicalities. So the DOJ regulation that was issued as we have the citations to on slide number 3, was issued in 1991 and it requires a self-evaluation of services, policies and practices that was to be done within a year of the effective date of the regulation by January 1993. So that''s what, 18 years ago now. And those were to be kept on file for 3 years. So what that basically means is an evaluation of how you--not only what you officially say are your policies, but what do you do on a day to day basis and how does it affect people with disabilities and how should your policies and practices be changed to avoid discrimination. And secondly, the 1991 regulation requires a transition plan, which means a plan that ensures that you don''t have discrimination that results from inaccessible facilities. That plan, basically, is to include a list of people you consulted, the areas you examined and the modifications that were planned to be made for the sake of physical access or program accessibility has to be done with public input and if you have--it''s also--it''s to be available for inspection for the public. And moving on to slide number 4, just briefly some of the other procedural requirements beside the self-evaluation and transition plan are that the modifications that are required for program accessibility have to be completed within 3 years. You have to have a responsible official whom we usually call an ADA coordinator, if you have 50 or more employees, and that''s the person who''s responsible for overseeing compliance, and then the office to be grievance procedures. There are 50 or more employees in other words, a way to file a complaint and a process for handling it. And then finally, to give notice to the public of what the ADA provisions are and how they apply to the entity. And then slide 5, we simply noted that Section 504 of the Rehabilitation Act also requires a self-evaluation and if necessary to ensure program accessibility, a transition plan. So let''s go on to the specifics. Slide 6, lists what the regulation says has to be included in a transition plan. Now, before we get to the details here, remember that a transition plan explains how you''re going to approach program accessibility. How you''re going to ensure that you are not discriminating because of inaccessibility, physical inaccessibility of your facilities. And I remember that you can do this by other means besides making changes to facilities. And the regulation tells you that program accessibility can be achieved by moving activities to accessible areas, by delivering services in other locations or to people in other locations, and through changes in policies and practices by purchasing new equipment, et cetera. So that is one of doing it and then an alternative is making physical changes. Now, I think and I hope that we''re seeing these other means being used less and less as time goes by as we see improve physical accessibility overall. But I do--I did want to mention, I think, we have to always mention this in any discussion about this, that there are options besides making physical changes to facilities. But if you do decide that you have to make changes, then this slide tells you what has to go into a transition plan. You have to describe what obstacles affect accessibility. And this is usually done building by building. And then you have to describe in detail how you''re going to remove those barriers, when you''re going to do it and if it''s going to take more than a year, you have to have annual markers. In other words, you have to say what you''ll do each year. And then you have to name the person who''s responsible for implementing the plan. So we asked a question in the next slide, slide 7. Why do a plan now? The 2010 regulation does not require a new transition plan or new self-evaluation. But keep in mind it requires compliance. You do have to comply with the regulation. So you may have done a transition plan when you are supposed to 17 or 18 years ago. You may have made all the changes you were supposed to make, it was self-evaluation and transition plan. But what if you haven''t done anything since then? Think about what''s changed and whether if you haven''t done an assessment or some sort, whether you can really still be complying. As you know, more and more people have disabilities and more and more people with disabilities are using the services as state and local governments wrap to about 18 percent of our population now in people with disabilities. And some of those disabilities are more severe than disabilities were 20 years ago. There are more types of disabilities, more diversity within the group of people with disabilities and people with disabilities are using more technology and types of technology that didn''t exist when you may have done your first self-evaluation and transition plan. And your programs have definitely changed. You offer more programs and activities if you''re state and local government than you did. These programs are offered in different ways and as a result, the building and facilities are used in different ways and when huge change that affects all of these is websites. They didn''t exist when the first regulation was--just after the first one came online about a year later I believe. And it''s definitely important to include an evaluation of your website as a part of a self-evaluation. So all these things have change and if they haven''t been reassessed then it''s not likely that you''re in compliance. Then of course change continues. We have new regulation. We have increased enforcement from the Department of Justice and Sally may want to speak to that and we have tighter economic times. Whether or not that will get better, we don''t know. But we do know that state and local governments are facing decreased resources and increased demands at least over the next couple of years. So you have to ask yourself, can you comply without a plan? How do you get somewhere if you don''t have a map or some kind of guidance for getting where you want to go? Which leads to another question in the next slide, is it better or not to assess the problem? Some people actually say isn''t it--some people might think, unless I know that I have a problem and I don''t do anything about it, I''m probably in more trouble than if I wasn''t aware of the problem. It''s not really true in my opinion. And the accelerator and the pedal there just sort of suggest problems that a car manufacturer, not to be mentioned. But couple of years ago had some issues partly because it is alleged that they didn''t addressed issues that came to their attention, safety issues in their cars. And I think if you look at the history of what happened with that, it probably would have been better to address the issues when they came up rather than allegedly ignoring them, keeping your head in the sand, not a good idea. Having knowledge and dealing with it is a better idea. So even if the regulations don''t require or no one suggest even that you do a self-evaluation or transition plan, there is certainly some benefits to doing a plan and we list some of those in slide 9. First of all, it shows good faith and it shows an effort to comply with the regulations. Now under Title III which applies to private entities, good faith is a consideration that a judge is to take into account and imposing civil penalties. It''s not specifically mentioned in Title II, but I think it is something that judges will look at and it''s also something that those--or use your services will look at after deciding if they have complaint how far they want to take it. In addition, it''s important to meet a new deadline including the one today under the 2010 regulations and keep in mind that there is always a possibility of harsher mandates from litigation. Basically what this means is a judge can order you to do what you should have done in the first place and if that happens it can cause you more to comply with the court order than it would have cause you to comply in the first place. That''s taking into account the class of damages and deaf lawyers, et cetera. And keep in mind, if you''re not controlling your own destiny, if you''re not in control of what you''re doing and what your plans are and how are you going to comply, then that can cause extreme disruption to your--through internal processes. So it''s better to be in control and to be doing the right thing without waiting for and taking the chance that someone is going to come along and file a complaint or file litigation against you. So with all that in mind, Sally is going to sort of walk us through the revisions that became effective today and the others that will effective in a year and what that means as you go through the process of doing a self-evaluation and transition plan. Sally.
Thank you Irene and happy March 15th, 2011, everyone. I''m going to talk a little bit about the regs and what I think what''s important to know is "why did we do what we did?" It was just--you know, people will say, oh, I just barely learned that and now you going to change it. The first thing that I really need to echo what Irene said earlier is that, yes, there have been some changes in the regs and there have been some changes to the 2010 standards. But really all of the fundamental underlying principles of the ADA in respect in Title II, things like, you know, program access, things like policy modifications and provision to be effective communication. I mean they--program access really hasn''t change and that is such a fundamental concept and that is something that as Title II entities as you''re looking at all of this stuff, you''re going to have to figure out how do you make decisions and we''ll talk about that later on for what needs to be done in terms of program access and that''s sometimes I want to say right up front, it''s a hard concept especially when you''re dealing with the new supplemental requirements. So we will--we''re going to talk about that. But my hope is that we have learned here at DOJ, learned a great many things in 20 years and when you stop laughing I will continue. We realized as Irene talked about it, technology has just incredibly changed the face of the United States of the world. And it affects so many things. It affects ways in which we communicate. It affects how folks with disabilities are living longer with very significant disabilities and they''re increasingly independent because of the use of technology. And we also look at it in terms of, for instance, the service members, the young men and women who are returning from the conflicts or wars in Iraq and Afghanistan who never would have survived even, you know, in the Gulf War of 1990. So we''re seeing a whole change of types of disabilities, the longevity of folks with disabilities and in the way we do business. And if you or other board, you can talk a look at the 1991 regs and our biggest technological issue there was I believe the baud rate of modems. And I think that was the only reference to any technology. So we know the world has change and we know we got things wrong and we know we need to clarify things and that''s why we did this. And there''s also federal requirement that we periodically review our regulations and we figure once every 19 years is periodically enough considering how long it took. Yes some parts of the regs are modified. There are new accessibility standards, those then theyre called the 2010 standards. And they basically incorporate the 2004 ADA Guidelines that the Access Board created. But we have also added in the regulation language there are a couple of things that if you look at, I''ll give you one that I know right off the top of my head, if you just look at the standards, if you look at for instance prison cells, in the standard it says 2 percent must be accessible. In the actual regulation it says 3 percent need to be accessible. So you need to look at the standards not just as a document on its own but where does--you know, what basis is in the regulation for getting us to the application of the standards. So don''t just think of the standards for accessible design, also think of them in terms of what do the reg say we have to do with those. So the effective date and I know it''s confusing because we use effective date, we also use compliance date. The effective date of the general nondiscrimination provisions in the Title II and Title III regulations are today, March 15th, 2010. Now, one, there''s a new provision for hotel reservation policies and because that is dealing with very large nationwide reservation systems, we give the hotels 18 months from the date that we published our regs which would be March 15th, 2012, because there is a significant amount of work that need to do on software and establishing systems to meet that requirement and the other, as Irene said, for the 2010 standards do not become enforceable for new construction and alteration until 2012, March 15th, 2012. So the next slide, 11 Robin I think, 2012 is the--that is the on the hook date for having to comply with the new standards for new construction, for alterations to achieve programming access through making structural modifications and barrier removal. Now let me tell you one thing before we go on, that is the date that the standards are enforceable and I want to give you, if close to advises I can legally do, and that is don''t wait until March 15th, 2012 to start looking at what you need to do. You need some time that''s exactly why that 18 month period was there to allow people to do assessments and figure out what is it that they have to do and to look at supplemental requirements. So waiting until, you know, March 14th, 2012 even though good faith effort is not specific in the Title II regs that just wouldn''t look good if somebody were to file a complaint. You are allowed to use the 2010 standards and we''ll talk about that in the next slide, but it''s--you are required, those are the only standards for which you can--you have to comply with as of March 2012. Slide 12, okay, here are the requirements for Title II entities. From now until March 15th, 2012, if you decide you need to make architectural changes to your existing facilities to meet program access. We have given you the options of choosing either to comply with either the 1991 standards. Now legally, those are the ones are still in effect or UFAS, the Uniform Federal Accessibility Standard which some of you folks may have used when you are complying with 504 or the 2010 standards. So between now and March of 2012, you can choose any of those three to use. However, that choice is gone on March 15, 2010 and that''s a really important thing to know because you need to think about which one--given your current situation, which one works the best for us. Because if you wait until 2012, you can''t make that educated choice any longer. Now the infamous supplemental requirements and these are requirements that are in the 2010 standards but--and this is for the first time that we have addressed this specific issues and elements. They were not in the 1991 standards. So they''re brand new requirements. So, you need to look at those and these are things like swimming pools, play areas, shooting ranges with firing positions, access to team seeding, and player seeding, accessible route to court sports and those kinds of things, waiting pools, spas, and like--things like saunas. There''s a whole list of them. These are brand new things for you and what you need to do is you have--and really March 15th, 2012 is your ticking date and you need to look at those things that you might already have and face it most Title II entities have some swimming pools and there is a requirement now that there be in excessive of 300 linear feet that you provide two accessible means of entry in egress and we didn''t have anything before in this. You need to be looking now at your swimming program or your pool program for your entity and figure out what you need to do to change things to meet those requirements and you do those to the 2010 standards because they don''t exist elsewhere. Next slide, number 13, existing facility I mean there were a number of things that were added to the Title II regulation that for whatever reason work in it before. And we have--we have added a very specific definition of existing facility which basically means it''s a facility that is in existence on any given date without regard to whether the facility may also be considered newly constructed or altered. And I know for some of you that''s like "well, duh. " But when we were beginning and it sort of stuck, that''s always been the department''s reading of what an existing facility is. But in practice what happened before, you know, in 1992 and 1993 the first question that was asked when somebody called us about complying with the ''91 standards was, "Oh, was this an existing facility or new construction? Because starting back then we sort of all in the same footing and that was a way of saying existing, oh, its program access or barrier removal. A new construction, you have to comply. These basically mean any facility that you have that is in existence and that''s it''s occupied. So if you built a building, a brand new building in June of 2012 that is--on that date that is an existing facility because it is a facility that it is there irrespective of whether it''s new construction or not so we added that definition. In terms of compliance for program access if you have to do architectural changes, you have to meet the standards in before 2012 in whichever standards you use for alterations but you would not be required to exceed those standards. And the question here on the slide is perfect so "what the heck if the measure changes?" And some measures--measured have changed. Slide 14, there are two different kinds of changes in the standard, one is incremental changes and the other is we refer to those as a supplemental requirements so those are new requirements that didn''t exist before, and incremental changes are things that were tweaked. They were in ''91 standards but the--either the scooping, meaning the number of elements that need to be accessible or in the technical requirements and that''s, you know, what are the measurements and how do you make something accessible. A lot of those things did change, and the question was, "Well, if we do that, are we going to make everybody go back and retool everything?" And the answer is no. So, if you folks have met your compliance in terms of bricks and mortar to meet your program access requirement or new construction or whatever it was you did, if that facility is in compliance with 1991 standards or UFAS, you don''t have to do anything to it. Let me give you my favorite example. Reach ranges have changed in the 2010 standards. For things like light switches, HVAC controls, and they were 54 inches in the ''91 standards but now it''s 48 inches for both a front and a parallel approach. It would be ludicrous for everybody to have to go and reposition all of those light switches and that''s an incremental change. So if you have all of your stuff appropriately mounted at 54, you don''t have to go wait and change it. There is one thing though if you do an alteration after 2012, then all of that in your existing facility have to comply with the new 2010 standards. But the key is, is that you are in compliance currently with UFAS or the ''91 standards and unless you do an alternation you do not have to make any further modifications to meet the 2010 standards even after March 2012. I''m hoping that this is clear. Next slide, 15 now, this is really what we''re working about as a safe harbor. And what this basically means is for me, safe harbor means if the weather gets bad you have to place where you can shelter. And that''s really what this is. Is that if you have done what you''re supposed to do and you meet the requirements, you''re not required to do anything further. But we are the Department of Justice and we never say anything without saying, however, we have some exceptions to those. And those are the new supplemental requirements. And again what I said earlier, these are requirements that are in the 2010 standards that never existed. They weren''t addressed in the ''91 standards. The safe harbor does not apply to this and the reason why is for safe harbor to comply--to apply to you folks is that you already have to be in compliance with ''91 standards or UFAS. And if there weren''t any scooping or technical requirements for certain things, how you''re going to be in compliance? So, these are new requirements and there isn''t a safe harbor. So you got--the bottom line is you got to fix them. And the last thing is--and I know this is really hard thinking about especially when we''re talking about the supplementary requires which are so bricks and mortars. And we''re talking about program access. And it''s very hard, I think, for folks--it''s almost like this is oil and water and it doesn''t mix. You have to look at what you need to do. Let''s talk about the supplemental requirements. Using the prism of program access, remember Irene had said earlier that there are a number of ways to provide program access and I completely agree with her when she said that hopefully, you know, having to move--relocate a program or deliver the service differently, hopefully there are fewer and fewer of those happening as the built environment gradually becomes more accessible. So, but program access basically what it says is that when you--you have to look at each program, let''s talk about swimming pools which as you know, there supplemental requirements for those. And for any Title II entity that has swimming pool, that''s a whole program that you offer. It is your swimming program or your swimming pool program, aquatics, you got it listed somewhere. You know, in a line item, you got it listed somewhere in what--if you go to your website which is always a really interesting thing to do is to look on your own website and see what you guys are saying you offer to the public because stuff changes and you might have a web master that all of the sudden throw something up and it''s like oh, I didn''t know that." But this applies to the program as a whole and I would love to see everything be made accessible. If you have 10 pools I would love to see them all be made accessible with two accessible means of entry, you know, lift, steps, a ramp. But the reality is, is that you may not be able to do that especially right now given significant budget constraints. So in order to make decisions you have to--you have to assess what it is that you''re doing now and my suggestions are is that you need to look at each of those pools and I know it sounds crazy because you''re thinking of pools, you know, what do I have to look at, it''s a whole in the ground. But there''s a reason why you put pools in the places you do. So, you know, how do people general participate in that? How do--do a geographic? If you''re small community who has two pools, you know, that maybe a little different. But if you''re a larger community and you do have these 10 pools, you need to figure out where they are before you can begin an assessment. And it may be if it''s a state county by county. If you''re, you know, town by town or could be neighborhood by neighborhood which is very common. Where I grew up in New Hampshire, we have neighborhood pools that the city offered. The next thing is look at what is it that you offer at each of those locations? How do you advertise each of those pools? Are there some pools that because of certain feature, it''s really geared for kids? Are there some pools where it may be a lot pool and maybe you have to be at certain age to participate to be able to use that pool? But you need to look at who is that pool intended for? Does it intended for specific age group, specific population or as we all know in our communities there are more and more folks with--who coming in--who''s primary language is not spoken English. And are there--do you make decisions based on that? There are certain things that we are going to put in certain areas and they''re designed to serve that area. And I think that''s a really important consideration. Now, so once you look at each of your pools and where they are, what do you offer at those pools then you need to look at which ones are accessible and to what extent are they accessible? And I think that''s a really important thing to look at because I would say that if you--if you had a pool that was fairly closed to being accessible but you chose not to make it accessible, you know, because it would cost too much and rather that they would go to other nearby pool, I think that might be problematic. So you need to look at what is the barrier to access? And if it''s a small barrier, you need--I think that you need to do whatever you can to remove that barrier because in this whole process and I know it sounds like a lot, but in this whole process you are required to get priority to methods of providing program access that provide--your programs in the most integrated setting you can. And so that has to be an important part of that calculus. And that goes back to why are you providing pools, where you do and what programs are you providing. And look at also dispersal and for a real small community, I mean what we''re looking at is how convenient are things is--is one--locate right in the middle of town and the other one you got to drive 5 miles. Or if you have the 10 pools, are 3 of them like really accessible pools ''cause they were the last ones you built and you, you know, went ahead and did stuff, but are they all on the outskirts of town not accessible by public transportation? So you also need to look to how do people get there and I''ll tell you there is a reason why you put things where you do and that has to be the important part of your thinking. You can''t ask folks with disabilities to--if they''re even able to get a taxi or to drive when everybody is able to use public transportation to get to a pool and that is an added hurdle and I think that that is different treatment. And then you look at, again, the existing barriers to participation. And I know we''re talking about the built environment but you also need to look at your policies as well to make sure that you may have some policies and on their face look just fine. You need to be careful that those policies also don''t unintentionally exclude people with disabilities. So, I mean, all of those things are very important in terms of looking at and answering the question, "Oh my God, what do we have to do now?" So two things, one is start now and the second is take a look at--do that assessment. Even if you don''t call it a self-eval, it''s fine, call it an assessment if it makes you feel better or if it doesn''t sound as onerous. But there is no possible way you can begin to look at whether you''re in compliance even by March 15th, 2012 if you don''t begin it now. And failure to do so just--if somebody were to file a complaint with us and our first question is going to be, needless to say, well, none of the pools are accessible. Our first question to you is going to be, "Hmm, so, let''s see your self-evaluation or assessment plan, how did you--how did you make the decisions not to do anything?" And you really need to be able to show something for that. You really do ''cause that won''t make us happy. And I know that folks who are ADA coordinators, and administrators who have a million things on your plate right now. But, you know, between now and March of 2012, compliance and assessment and evaluation of where you stand in terms of providing access to folks with disabilities, you need to be doing that now and you really--you have to have something to show that you''re trying and are you going to--if you have to make structural changes at everything that you''re going to be able to do that right away, the answer is, you know, maybe not. But even if you gotten that far and you make that assessment then don''t let the process stop. Then say "Well, here''s what we can do." And Irene and I will talk to you about transition plans but you need to look now, figure out what you can do and start implementing things bit by bit by bit whenever you can. And you know, for those who wait until, you know, March 12th of 2012, March [inaudible]--see I changed the date, March 15th of 2012, I really do think you do that at your own peril. So I think what we''re going to be doing now is talking about how do you do a transition plan or whatever it is you call it. And what do you need to be thinking about. And we''re trying to put this in perspective and to make as easy as possible. And yes, I''m from the federal government and I''m here to help you. So with that, I think I''ll turn this back to Irene.
Thanks Sally. We know you''re here to help, I remember. We''re going to talk--Before we get to transition plan, we''re going to talk a bit about self-evaluations and we don''t have a slide for this, forgive the oversight. But when you do self-evaluation, you''re looking at your policies, in other words, what you officially say to your staff or to the public if you''re a city, town, state, et cetera. What do you say you do with respect to people with disabilities or just as important what do you say your policies are and how do they affect people with disabilities? Because you may have policies that aren''t specifically disability related but still have an impact on people''s disabilities. So you look at your policies and then you''re also looking at your practices which are it sort of what do you on a daily basis. How do you carry out your programs? You know, if you say, "Well, we''ve always done it this way. That''s a practice. May not be a policy. It may not be something that''s come down officially but it''s a practice or you''re also going to look at your procedures. How do you--what officially do you say is a way in which you do something. And you need to do that in the all types of areas. It can be very board ranging and of course the larger city or a state is the more types of activities they''re likely to have. And some of the things that I''m going to talk about are going to be geared more towards larger entities but keep in mind that you need to tailor what you do to the size of your entity and the types of activities that you carry out. I''m currently working with teams on doing self-evaluation and transition plans for a major city and for state university and we''re taking the same approach to this. And basically the approach is this, we work with the entity to--we trained them to do their own self-evaluation and transition plan with our help. So the first step is to identify all the programs by--it''s usually department or agency and then we trained staff. We train a team from each department or agency about how to use a survey form that we developed and that''s in Excel and then has a number of questions and the ones that we have are numerous and detailed again because these are large entity. Small entities would probably do this a little bit differently. Once the training happens we ask the teams to, base on the knowledge they''ve gained, go back and identify the programs again and see if these really are individual programs. And by programs, you know the definition that''s kind of elusive but we mean is a particular identifiable activity or service or sort of a cluster of activities or services that have common elements that are carried out or administered in the same way. Then the department teams or agency teams fill out the survey form for each program and they do this in Excel and then they have a database from which to work. So for example here are the kinds of things that are covered. We have a section on the application process. In other words if people need to file an application in order to participate in a program or service, how do you carry that out? We have one on illegibility to participate. We have one on testing, one that would apply almost any kind of entity as hearings, meetings, trainings, classes, tours, and special event. Modifications of policies, specialized program do have, for example, a wheelchair basketball league in the city then we ask you to analyze that according to the provisions of the ADA with respect to most integrated setting and specialized programs. Communication including in-person communication, written communication, oral communication, telephone, electronic communication, websites, maintenance of features, transportation, emergency procedures. So, all of these are the kinds of things that almost any entity would need to evaluate. And then other areas that is specific and that not, that some of the small towns might not have is housing. Sally mentioned recreation activities like pools, those are something that are covered as well, city sheltering programs for people who are homeless or have survived or victims of domestic violence, access to libraries, community policing and community policing meetings. So, what we do is we ask each team to sit down with other people and to know within their department or agency and we sit down with them and they do the first couple of these and go through this whole series of questions. And the first stage is gathering information and we try to emphasize to people that you''re not making decisions and recommendations at that point, you''re gathering information. You''re detecting whether there are problems. So for example and I''m just going to give you a couple of these so that we can get to questions pretty soon we may ask, well, let''s take service animals ''cause that''s one of the areas that''s not changed in the new regulation. We asked--We have a section on modifications of policies and one of them is--one question is can a person ask for changes to a policy or procedure and then yes or no and then if the answer is yes, how do you decide whether to agree or modify the program, the policy or procedure. And the next question is do you allow service animals in all location where the--where a service is offered to the public and then we have more specific questions, do you limit the questions that can be asked and of course we say what those questions are under the regulations. Do, you require special permit, do you require this? Of the course, the answers to those two should be no. Do charge fees and then is your staff trained on this? And for meetings we''ll ask, are they always held in accessible location? If they are not, do you move them, how much notice do you require, what kinds of notice do you give to people, et cetera? And we go through those kinds of questions with every single category which then gives you a database which I think is essential for any kind of decision that you''re going to make. And again, if you''re a small town or a small county, you''re not going to ask as many detailed questions. You''re not going to be covering as many--as many areas but this is a model that seems to work well at least so far with a larger city and I think it would also work with city of moderate size and with almost any size of university. So then once you''ve--you''re doing a transition plan and a self-evaluation either concurrently or you can do them separately. And if we go into slide 17, we mentioned that there are different--there are several ways to do a transition plan. And I remember when we were at justice and Sally, you''re probably still having these conversations, the question was do you look at the program and then look at each facility is in the program or do you look at each facility and figure out how each used in one or more programs. Do you follow the program when you follow the facility?
Yes indeed we do still get those questions.
And do you have an answer?
I say whatever works best for you.
Absolutely. I would say the same thing. And I think generally a hybrid is going to work for most instances where you''re considering both the facilities and how they''re used at the same time and it can get tricky, it can get difficult. You can get mired down in a lot of detail and I think prior to the trick is knowing your own programs working with someone who--if you don''t have in house ability working with someone who thoroughly understands the requirements to the extent it can be understood. And figuring out what works for you which leads us to--on slide 18, we say do what works for you. There are various models. It''s important whatever you do to identify what you''ve done as a self-evaluation, as a transition plan, or if you''re a Title III entity as a barrier removal plan. You know, don''t be in the position where somebody says did you do one? And you say "Well, we talked about it." We might have something somewhere. You need to have it labeled as your transition plan or your self-evaluation. And when you''re doing your transition plan, it''s important to look at how policies affect access to facilities. In other words, you can have a beautifully, perfectly accessible facility. But if you lock the accessible entrance, if the inaccessible entrance open or if you don''t maintain features to be accessible then you''re basically creating barriers. And you also have to look at outside entities who worked with you, who may supply the--for the parties and events or who may actually carry out some of your programs such as homeless shelters, child care, et cetera because you are responsible for what they do. It''s important to consider them and include them in your planning and your evaluation for the same extent you include the things that you do directly with your own staff. So, Sally do you I want to chime in here and give us the benefit of your experience before we go on to the others?
I mean, I think I really do and I agree that the hybrid is probably the way to go if you can. But then there are some things that I think you need to look at ''cause remember early we talked about that relocating or moving, you know, or delivering the service differently is one way to achieve program access but I think you need to look at--there are some things that you can''t--deliver it differently. And I think you need to look at those and perhaps identify those and that all goes back to why you offer the programs you do in the way that you do because there were some thought process even if it''s what we''ve always done it this way for 96 years. There''s a reason why you do things the way you do and I think you need to look at those because if you use other methods other than architectural changes one thing that I really I want to caution folks about is that if you deliver the service differently or if you relocate where--to an accessible location where somebody can access that program, activity, or service. You have to make sure that they''re basically equal services that the same terms and conditions. For instance, I mean, say if I have to come and register my car and it''s always been that room on the second floor of my town hall and there''s no elevator, you know, they couldn''t remove a barrier but it would need the program access requirement for them to come down and say, you know, we can do this in the lobby. However, if that same town hall houses on that inaccessible second floor, a group counseling sessions for survivors of rape. You shouldn''t be able to say to me that, you know, we can, you know we''ll talk to you one on one in the lobby. So, there''re two things that will be incredibly wrong with that. One is, is what is the benefit of the program? And you don''t have group therapy or group counseling just to have it. There is a different kind of benefits and it''s a different kind of a format. And it''s always done behind closed doors. So meeting me in the lobby to talk one on one pretty much gets two big, red Xs because it''s not the same program and it''s not under the same terms and conditions. So, I think you need to be thinking of again, how do we open this program generally and how people participate? And if you think it''s important to do something in a specific way, you have to make sure that you do that in a specific way that is inclusive of people with disabilities as well.
And along those same lines, you talked about how the relationship with the facilities, the activity is so critical sometimes it''s the neighborhood that matters also. For example, all around the country, we have community policing programs and, you know, you may live in a neighborhood where there has been, you know, maybe a rush of breaking a windows of cars at night or a series of violent attacks. And police will call a meeting at the local school or the church or whatever for those in the community. Well, if that''s not accessible, it''s going to be hard to--you''re not going to--so you I want to move that to the neighboring community if that''s the only accessible location you have. So you need to plan in advance for an accessible location. And by accessible, I mean not just accessible to people with disabilities but accessible to the community, and the people with disabilities in the community. So in that sense, it''s very closely tied to the particular community. And another area where this comes up in higher ED is housing. Residents'' halls more and more has special, so to speak, programs housed in. And there may be tutoring, there may be foreign language house, a French house or a Spanish house. Residents'' hall that''s used by most--that''s favored by most of the athletes. People may prefer to be in a certain location. All those factors come into play when you''re assessing whether the housing that''s offered to students and faculty even with disabilities and higher education are accessible. So, all these factors need to be taken into account. Sally; are we ready to take questions?
I think so. Go ahead. Robin Jones: Irene will have the operator go ahead and give some instructions to people about that. And then we can take up questions from folks. So why don''t we go ahead and do that right now.
Ladies and gentlemen, if you have a question at this time, please press star then 1 on our touchtone telephone. If your question has been answered or you wish to remove yourself from the queue, please press the pound key. Again, if you have a question, please press start then 1 on your touchtone telephone.
While we''re waiting for people to do that, Irene and Sally, I''ve got a couple of questions that have been submitted already through the electronic means. One of them is I have a participant asking whether or not you know, of either one of you, any cities, towns or states that you find to be more progressive with compliance with--you know, that may already started look at the new regulations and such that you might, you know, recommend through somebody who is looking for, you know, some best practices or whatever. Are you, either one of you familiar? I know it''s kind of difficult to name names and such, but are you aware of anything?
I can mention one or two things I think. Now, I don''t know what they''ve done in light of the new regulations. But when I am looking for good practices, I find that the city and county in San Francisco is a good place to look. And I didn''t ask them if I could say this. But they have some pretty detailed policies and practices and checklist for special events for example. And they develop their own self-evaluation. Now, I would go online and Google and see what you can find. There are some good examples out there. When you say that it''s about their own self-evaluation, one of the other questions that was asked is do you have any tools or recommend any tools, checklist et cetera that would be available to entities to do this kind of thing. Now, this is the eternal burning question. The New England center--oh, that''s an environment, excuse me, what used to be adapted environment, did the ADA Title II action guide when the original regulations came out? And I think that still, one of the most helpful guides although it''s not terribly detailed and of course it''s not in Excel or anything like that, I don''t know. A lot of the cities have copyrighted or don''t necessarily make available their checklist. But I know San Francisco is online and I think that''s a good place to start. And I''m hoping that more will be developed as time goes on. I don''t know Sally if you know of any?
Well, I mean we have just in on our ADA website which is www.ada.gov. We do have a toolkit and it''s under a project civic access. And if you don''t know about it, we have the authority to do compliance reviews at a town near you. We developed seven chapters of--it''s called the "PCA Toolkit" and it''s online. In chapter 2, deals with, you know ADA coordinator stuff, notices, grievance procedure, and administrative requirements under the ADA. I have seen an awful lot of private stuff and I can''t speak to their accuracy. I don''t--well, Irene, what about--what about NADAC did they do they have stuff on there?
No, they haven''t developed it. But I think the toolkit is a great place to start. It''s not complete yet but I think chapter 2 with the procedural bits, I think the information justice is developed from emergency shelters is absolutely outstanding. And I think it''s the right level of detail to use for those purposes. And the other sections in communication are well done as well. Yeah, I would definitely use that to the extent that--you know, the parts of that that are done are just great I think. We found that we had to basically draw from what other people had done and come up with our own approach to this. There is just nothing that''s comprehensive I guess yet.
Yeah. And I think one of the struggles is that because every entity is different. I think that some--of not having something that is, you know, uniform or out there, is because there is some need to kind of customize or look at for yourself and what works with your organization and how you approach it and what you are going about. Often times, I think entities are looking for cookie cutter and it doesn''t always work cookie cutter in these situations because programs and services do differ on how you organize, you know, does differ.
Right, yup.
One of the other questions that we have here is I think as you alluded in some of your comments to the preamble, for the county regulations. And we have somebody who''s asking about whether or not this is actually posted on ada.gov and where they would find it. So Sally, can you--do you I want to give anybody some specificity of how we might find that ''cause there''s so much information on your website to try and find this particular document. Do you have any suggestions for people? I think that''s what they''re asking.
There are a couple of things. One is that we have--first of all, we have prints, copies available. We just--Oh, a month ago I guess, we''re able to print the fully integrated regulations. Now, up on our website, there''re two things you I want to look at. Right now on our website, we have an HTML version of the integrated regulation which basically means the regulations that were published last September are not the full Title II reg. What they are is they''re additions and changes. So only that was published, not the full regulation. So here is a suggestion, is look at the federal register version on the web and you''ll find it. It''s right near the top of the homepage for regulations. And that will have the language, the guidance or preamble. It''s now called guidance, section by section analysis that relates to the new provisions. All of the text of the other parts of the regulation and the old preamble stayed the same. We are hoping in the very--well, in the relatively near future, we are DOJ after all, to be able to publish HTML versions and a PDF version of our printed reg which includes everything. And it also includes the 1991 preamble, so people can have that as well. But we don''t have a complete reg document up there yet.
Great, thank you. Why don''t we go ahead and take some questions from our calling participants, please.
We have a question from the State of Indiana.
Go ahead.
Sally and Irene, thanks for holding this. I have two questions if I can, one is real quick. The integrated regulation, does that include the corrections that were just released?
No.
Okay. My question was if a particular state agency, it chooses to use the 2010 standards right now, that this obligates another state agency to use the 2010 as well?
My answer to that would be no because it''s not necessarily by agency, because the standards deal with the built environments and facilities and building. So I mean you would--you have the choice of using ''91, 2010 or UFAS for each facility, and you have to stick with that throughout that facility.
Right. But if there was a particular agency, let''s for example the Bureau of Motor Vehicles decided to use 2010 and their new construction would the Department of Corrections have to use 2010 right now?
I do not believe they would. I don''t see any connection, Irene?
I read it the same way you do, Sally.
Great, thank you.
Our next question comes from ADA Ohio.
Go ahead.
Hello. Actually, you answered our question so you can give the floor to somebody else, just a hello to Irene and Sally.
Thank you, Scott. That was Scott. [Laughter]
That was Scott Lissner if anybody wants to know what that--in compliance office at Ohio State University that was talking though, that people were saying hello to. I do have an online question. I want to flip in here at his point. We have brick and mortar question as they say. If a facility is not in compliance of the 1991 standards or UFAS, and the programs offered in that facility has been made accessible through alternative methods, do alterations have to be undertaken to bring the facility into compliance with the 2010 standards?
Okay. Let me give the official answer, is--is no because you''re looking at in terms of program access. So--But what I would caution is that now is a wonderful time to look at, are we really offering these things in an integrated setting, Irene?
I totally agree with you.
But for example, in this case, let''s say that they were offered into an alternative means such as, let''s say, we have our home visit instead of actually having the person come. That could be an issue of what you''re saying the integrated setting. Because if everyone else is coming and has the benefits of the other interactions and things that occur by coming to a site, that that is something they should readdress.
Yeah, I think they should because, you know, integrations, it''s--it''s so key in the ADA that''s specifically mentioned. And, you know, things may have changed now. And, you know, maybe they''re able to either offer that whole program in an accessible facility or make some other changes. An assessment is still due.
Right. You''re talking about at heart; this is about program accessibility, and whether you''re actually achieving program accessibility. And if Sally has suggested and I think that''s wonderful to emphasize this, integrated setting is important, socialization is important, confidentiality. All those factors go into whether you''re achieving true program accessibility. And if you''re not, then yes you will have to bring up--upgrade the facilities to bring them up to the standards. But I think you go back to that first core question, what is program accessibility and have we achieved it? And if I could add one thing, I mean when you look at when the ADA regs were--you know, were promulgated back in the early, early ''90s, nobody was in compliance with anything. And they were--I think that there was a very different expectation then, because the built environment was incredibly hostile from decades of neglect. And I think that there is a different expectation this time around. I think that perhaps local governments may have more alternatives now. Is it perhaps less convenient? Maybe, but I don''t think that that is a benchmark for deciding what program access truly is. I want to mention something that we haven''t uttered. We haven''t uttered these words yet. But I think we have an obligation to mention it. Program accessibility has some limits I guess you would call them.
You don''t have to do anything that would cause an undue financial administrative burden. You don''t have to do anything that looks fundamentally alter the nature of a program. So, you know, we''re talking about the ideal in many--in many respects here. It''s ideal to have the most integrated setting and then the same level of confidentiality and the same level of socialization and convenience and all of that. But part of what you do in a self-evaluation and transition plan is to make decisions. You gather the information. You decide whether you really achieve program accessibility. And if you haven''t, you decide what you''re going to do to work towards that goal. But you do have those limits. And especially when everyone is struggling with decreased resources, you then make decisions about what you''re going to do and what you aren''t going to do. And at this same time, you don''t throw up your hands and say, "It cost too much. I''m not going to do anything." If you decide to take advantage, so to speak, of those limitations, you need to do that in writing. You have to have the head of the agency or somebody who holds the purse strings. Put in writing what the decisions are that you''ve decided--for example you decided to make these 3 out of 8 pools or libraries or whatever accessible in this way. And the reason you''re not doing the others even though it would be required for full program accessibility is, you give your reasons, you document that, you make sure that you consider all the funds that are available, and then put that in your plan, put that in your self-evaluation that''s required by the regulation. And then also, is one of the measures that will help protect you from liability if anyone challenges you. I mean I don''t I want to --I don''t I want to sound like we think, you know, all of your resources have to go towards this. But there are those limits. They''re written into the regulation.
Yeah, I agree completely. And yup, sometimes we do talk about the ideal situation. But the ideal is what hopefully we need to strive for. It doesn''t mean you''re always going to need it. Or that you''ll, you know, really be able to need it, you know, in a lot of situations. So yeah, I just I want to echo what Irene said, that there are limitations or defenses should you need to have a defense. And you may say in your self-evaluation and transition plan, here is what we''ve done and here is what we know and need to do. And I mean these three things are priorities in the next 5 years, you know, state what goals you''re working towards and how you plan to achieve those.
Okay. Next question please.
Again, ladies and gentlemen, if you have a question, please press star then 1 on your touchtone telephone.
So does that mean we kind of a--we have kind of silent group there today, many obviously questions and things of that nature. Maybe they''re pondering out or they''re overwhelmed as all of us are by this. If you had anyone, you know, suggestion for a Title II entity, let''s say that has never gone through even though they were required and those quote-unquote, you know, requirements have now come and gone and I know you may comment to this in the beginning about this issue. But if you had any, you know, one recommendation for a Title II entity whether it be a local government or be a state around how to approach the compliance today, 20 years after the implementation of the ADA in light of, you know, the new regulations at this time. What would that be, both Sally and Irene if you I want to take a stab at that?
I''ll make one suggestion. If you''ve never done anything and you don''t--you''re not going to know how well you''re doing necessarily, I would reach out to the community and start there. You could do--You could start by asking people come into contact with city workers to fill out a survey or to answer some questions or to do it online. And it wouldn''t necessarily be people with visible disabilities because some disabilities aren''t. Or start with community or public meeting to sort of start assessing where you are and where you need to go, and then come up with a reasonable planned approach that works with you. And that last part I know is really fuzzy and vague. But I wouldn''t just sort of think nothing is going to happen. We never had to do much before. Another piece is to look at those things you do where you have the most interaction with the public and start evaluating how successful those are, how effective those are for people with disabilities, and look at communication, look at what you do for public meeting, for web communication and your written publications, those are just some ideas.
I have a couple. I think the first would be is to take a deep breath. And just, first of all, don''t believe everything you hear except from Irene and me. Or everything you read. And I think that you need to know what questions you''re going to--if you''re going to--and I think outreach is incredibly important. And not just to folks with disabilities but also to, you know, the baby boomers and the aging population, because I think one thing is don''t assume that you know what the priorities might be. And it may be something that you think, well, this is like the biggest. It''s going to cost the most money, so that maybe should be our first priority. When you get feedback from folks who need those accessible features, they''ll say, "No, I could care less about that right now. Here are the big issues." So when you do outreach and you look at, I think you have to go back and look at who are the audiences that you are trying to provide services and programs and activities for. And that''s going to help you identify who you need to get feedback from. Sometimes if you get feedback just from a wide open space, you need to be careful what you wish for. And I think if you can identify who users are and talk with them about, you know, specific programs or facilities, I think that''s very helpful. But the important thing is to act and I think, you know, probably folks that are out there and are ADA coordinators, you know, whole a lot of you were an ADA coordinators back, you know, when the self-eval and transition plan was due 18 years ago. So the important thing now is to just begin and I would suggest that you reach out to other ADA coordinators or whoever might have that title or to all those folks who have these duties in there, other duties as assigned, category. But talk with others and, you know, we''re all going to make mistakes and I think perhaps that''s the most important thing. And the important thing is that you start to pan, you start to assess, you start to do an eval, and yeah, you''re going to make mistakes. I mean who isn''t. And just be prepared to fix those mistakes. And even if you do make mistakes, our interest here at the department is stopping a discriminatory practice, which may be an inaccessible built environment, a policy or a practice. And what we care about is fixing that problem and that''s our interest. And if you have done the best you can and it''s clear that you''ve tried, we''re not going to be seeking penalties or seeking financial compensation. But I''ll tell you what, we will be seeking them if it''s very clear that nothing has been done, not just for this time around but for the last time. And to follow up to that, Sally, ''cause we''re almost at the end of the hour, do you feel or can you give any thoughts and maybe you don''t I want to , you know, check the card or anything. But whether what DOJ''s approach is going to be towards monitoring entities at this time, I mean given the heightened awareness with the new regulations and the confines and, you know, effective dates and such of that nature, do you have any sense of whether or not there is going to be some step up monitoring going on at all or just going on as you have? We''ve checked they''re going to be step up in this administration already but just--if you can give any thoughts on that? Well, I don''t know in terms of monitoring because we''re not going to go in--we''re not going to go to a title to entity and say, "Alright, how are you doing with all of this stuff." Unless we have an intention to do a compliance review. So, I think a lot of this is still going to be what we get for complaints from folks who are living in these communities. What we hear and we hear a lot, you know, and from folks "on the outside," but certainly the expectation is that especially the second time around, yes, people are going to make mistakes. But I wouldn''t be surprised if we don''t do additional litigation, if people won''t so.
Yeah, okay. I think that''s good. Well, we are at the bottom of the hour. That''s always the problem with these things is we do end up having a lot of dialog and we do end up running out of time. We are at the 2:30 mark and I want to thank all of our participants for their engagement with us today and their participation with us. Just as a reminder to people that our next session which is in April, that session will be covering the recreation areas and will be given specific focus on the new areas of recreation that are in the 2010 standards. And one of the points of discussion there will be, you know, how do I begin to look at those issues for compliance? And you heard our presenters. They talked about the issues of safe harbor and what does and does not apply to those things. Our speaker which includes the new issues of the new recreation areas, our speaker for our next month''s session is Jennifer Skulski who is with the National Center on Accessibility, and does a great deal of work in the area of accessibility of the recreation environment. So I invite you to join us for that session. And you can go to the website, www.ada-audio.org to register for that particular session. And we invite you and hope that you will come and join us for that session. I also, at this time, would like to remind people of the upcoming events. One most importantly is the National ADA Symposium which is scheduled in May of this year. It is in Las Vegas. And this year, this is an annual event that is sponsored by the network''s ADA National Network. And this year, it is on the 9th, 10th, and 11th of May. Registration for that event is available online as well. For those of you who have not had an opportunity to--or are not familiar with it, it''s adasymposium.org, all one word. And you can get all the information you need, great room rates, as low as 59 dollars a night. Registration, early registration, 50 dollars and then it goes up after that, so up to 600 dollars so you may I want to think about that. You may also I want to contact your regional ADA center to see if any scholarships or any [inaudible] are available to attend. So I really do encourage people to look to that at the national event. And I know Sally, you will be there and be presenting. And I know you will be covering some of the new regulations and things of that nature as part of your presentations and such. So I do want just to make people aware of that. So this concludes our session today. You will receive a follow-up email with evaluation link. We do encourage you to give us feedback. We use your feedback to try to improve our program and such. So please take some time just fill that out. And before we leave today, I do I want to extend a huge line of thanks on behalf of the ADA National Network and our participants to both Sally and Irene for sharing your expertise today and being frank with us in your discussion on this particular topic. There is a lot more to be learned by all of us and it''s an ongoing compliance issue that we all deal with on a day to day basis. So thank you very much and everyone, have a great rest of your day and as I said, discussion was recorded and will be available within 5 to 7 business days on our website at the www.ada-audio.org in the archive area. Again, thank you very much and you can now hang up your phone or disconnect your computer. Thank you.
Ladies and gentlemen, thank you for your participation for today''s conference. This concludes the conference and you may now disconnect.