Re: ADA Section 508 Compliance on StudentLoans.gov?

  • From: Jamal Mazrui <empower@xxxxxxxxx>
  • To: programmingblind@xxxxxxxxxxxxx
  • Date: Sat, 17 Jul 2010 11:13:26 -0400

Don,
As far as I can tell, the the web site you tried to use does not comply with regulations of Section 508 of the Rehabilitation Act. The DirectLoans.gov site appears to be run by the U.S. Department of Education, which describes its 508 policy on the following page:

Assistive Technology Program: Testing For Web Accessibility
http://www2.ed.gov/policy/gen/guid/assisttesting.html

The page includes the following 508 rule:

“(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.”

The page states that this rule is "designed to assist the blind because it impacts their ability for accurately filling out forms on the web."

Although the U.S. Government can be sued under various laws, only administrative complaints are permitted under Section 508. I can assure you, however, that federal agencies currently take such complaints seriously. In fact, federal officials interested in proper implementation of such laws often appreciate receiving a complaint that illustrates their importance, as I think yours does.

For your information, the National Federation of the Blind filed a complaint against the Department of Education about another of its web sites, described here:

National Federation of the Blind Files Complaint with United States Department of Education
http://www.nfb.org/nfb/NewsBot.asp?MODE=VIEW&ID=491

Although the NFB used a law firm, that is not necessary. I think the Section 508 coordinator at the Department of Education is Don Barrett (a helpful guy). His email address is

don.barrett@xxxxxx

A complaint like yours presents a compelling personal story about the need for 508 enforcement. It could have significant impact on web site practices, not only at the Department of Education, but at other agencies as well. Even though you may have completed the form with telephone assistance, I encourage you to follow up with a written complaint.

Best,
Jamal



On 7/17/2010 2:52 AM, Donald Marang wrote:

Today I attempted to sign a Master Promissory Note on StudentsLoans.gov
for my daughter. It was one of the most important on-line transactions
and worst experience I ever had! This is a US Government site and as of
July 1st, became a monopoly because all of these loans are now directly
serviced by the government, not a variety of commercial banks. The
entire site is what I would call unusable for screen readers! The site
and its sister site for filling out the student's financial aid needs
(FAFSA)require you to fill out forms. The forms are nearly impossible to
fill out! The biggest problem is a focus issue. After filling out a
field and pressing Tab, the focus moves randomly around the page! Even
signing in requires you to enter Social Security number, first two
letters of last name date of birth, and PIN. Both SSN and DOB require
you not to enter dashes or slashes and fill them in for you in a
semi-secure password field. The example says to enter in mm/dd/yyyy
format, but if you do the log in fails! Again, it is impossible to fill
out more than two of these fields without losing focus and returning to
the top of the page or elsewhere. I had someone from the hotline on the
phone for two hours to simply electronically sign a document!
I has similar and worse experiences on the site to create the PIN and to
fill out the long FAFSA application. For instance, there were at least
three definitions for how to calculate the number in your household. I
needed to go back into the FAFSA after completing and submitting the
application. The page to correct the form is very bizarre and has the
information as previously entered in a column and then a field in a
second column to make the correction appears if you click to change that
piece of data. Again, the focus is a major issue on this page. I was
very careful about just changing the number in household number. I found
out later that night when calling their hotline a completely different
question, that the agent told me that there was no longer a last name on
the application! Since the last name and Social Security number are part
of the sign in process, it was impossible to correct on-line and had to
be handled by snail mail!
I thought all government sites had to be accessible by ADA law. These
sites are particularly Important to the blind! Is there a department of
the government to report such sites? What are the relevant regulations /
laws in this circumstance? What are the possible actions / reparations
that can be taken? I thought it was impossible to sue the federal
government. However, Social Security was recently required to send blind
people letters on CD or large print if requested. That was the result of
some type of legal action.
Don Marang
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