July 15, 2024
Stacy Murphy
Deputy Chief Operations Officer/Security Officer
Office of Science and Technology Policy
Eisenhower Executive Office Building
1650 Pennsylvania Avenue, NW
Washington, DC 20504
RE: Doc. 2024-11838
Dear Ms. Murphy:
The National Federation of the Blind appreciates the opportunity to comment on the Office of Science and Technology Policy’s (OSTP) request for information (RFI). Additionally, we commend the OSTP for the development of the forthcoming Federal Evidence Agenda on Disability Equity, as we believe there is still much to understand regarding the disparities in data between individuals with disabilities and our non-disabled peers. We have taken this opportunity to craft responses to the most pertinent questions in each of the three areas outlined in the RFI. These questions, and our subsequent answers, are below.
Describing Disparities
What disparities faced by individuals with disabilities are not well-understood through existing Federal statistics and data collection?
Answer: Current disparities faced by individuals with disabilities that are not well-understood include, but are not limited to, a lower graduation rate and lower employment rate than our non-disabled peers. Federal and independent statistics and data collection both effectively measure this disparity, but there is little information to understand the root cause.
What types of community-based or non-Federal statistics or data collections could help inform the creation of the Federal Evidence Agenda on Disability Equity?
Answer: Data collections regarding the individualized education plans and whether those plans are being appropriately implemented could benefit toward understanding disparities in graduation rates. Additionally, we believe it would be important to understand how many students know, or are being taught, Braille. Similarly, data collections regarding the tools and methods implemented to accommodate employees with disabilities could be helpful in understanding disparities in employment rates. Furthermore, we believe it would be immensely helpful to have this information broken out by specific type of disability. For example, blind and deaf should be separated and not combined as “sensory disabilities.”
Community-based research has indicated that individuals with disabilities experience disparities in a broad range of areas. What factors or criteria should the DDIWG consider when considering policy research priorities?
Answer: In addition to the different data sets mentioned in the answer to the previous question, the working group should consider the current legal requirements by educational institutions and employers, and how those are being enforced by the various government agencies that oversee those areas.
Informing Data Collections and Public Access
Disability can be defined and measured in multiple ways. Federal surveys and administrative data collections use different definitions of disability and measure it in different ways depending upon the goal(s) of data collection. What frameworks for defining and measuring disability or specific considerations should the DDIWG be aware of?
Answer: The working group should operate using a single definition of disability, regardless of the goal(s) of the data collection. The most appropriate and well-known definition of disability is that used by the Americans with Disabilities Act (ADA).
How can Federal agencies increase public response rates to questions about disability to improve sample sizes and population coverage?
Answer: The quickest and easiest way to increase public response rates to questions about disability is to ensure that the survey or data collection tool being used is accessible to people with disabilities. This will ensure that those most affected by the policy in question are able to provide feedback and information regarding their experiences.
What barriers may individuals with disabilities face when participating in surveys or filling out administrative forms?
Answer: The largest barrier is accessibility. For example, a paper form is not accessible to blind individuals. Any survey intended to be answered by a blind person should be distributed in an accessible digital format or via an automated telephone system that can be completed using a touchtone phone, since not all blind people have equal access to the internet or updated computers.
How can Federal agencies best raise public awareness about the existence of sources of disability data? How can Federal agencies best communicate with the public about methodological constraints to collecting data or publishing disability statistics?
Answer: Public Service Announcements and radio and television advertising campaigns could be used to raise awareness about disability data.
How do individuals and organizations external to the Federal Government utilize data from Federal surveys and administrative data collections? Which practices employed by Federal agencies facilitate access to and use of these data? Are there additional practices that would be beneficial?
Answer: The National Federation of the Blind frequently uses employment statistics collected by the American Community Survey (conducted by the United States Census Bureau) to illustrate the disparities in the employment rate between blind and sighted Americans.
Privacy, Security, and Civil Rights
Unique risks may exist when collecting disability data in the context of both surveys and administrative forms. Please tell us about specific risks Federal agencies should think about when considering whether to collect these data in surveys or administrative contexts.
Answer: We encourage the collection of information regarding disability because it helps to evaluate existing policies and inform new policies. However, it is important that this collection does not encroach on the privacy of individuals with disabilities by requesting private and confidential medical records.
In closing, we thank you again for the opportunity to comment on this RFI. The National Federation of the Blind believes that the data of increased specificity, as outlined above, will lead to a much more equitable future for blind Americans. If there is anything else that we can do to help, or if you have additional questions, please do not hesitate to contact us.
Sincerely,
Mark A. Riccobono, President
National Federation of the Blind