by Melanie Brunson

On May 20, the Bureau of Engraving and Printing (BEP) published a notice in the Federal Register outlining the recommendations they propose to make to the Secretary of the Treasury regarding how to provide people who are blind and visually impaired with meaningful access to U.S. currency. Before finalizing their recommendations, the BEP is seeking public comment on their proposals. Comments are due by August 18 and both individuals and organizations are encouraged to provide input.

Below is a summary of the BEP proposal, and a list of some of the specific questions to which they are seeking answers. Space does not permit us to publish the entire notice here, but if you would like to read it in its entirety, visit http://edocket.access.gpo.gov/2010/2010-12091.htm or contact the ACB national office for a copy in electronic format or on tape. BEP Recommendations

I. Tactile Feature: BEP will develop and incorporate a raised tactile feature that will accommodate people who are blind and visually impaired. This feature will enable blind and visually impaired individuals to identify currency by touching the tactile feature. According to BEP, their study demonstrated that raised tactile features allow most blind and visually impaired individuals to denominate currency. Indeed, this kind of feature is used in some foreign currency, and the study's data indicated that this feature was more effective than virtually every other kind of accommodation tested, including different-sized notes. Additionally, a raised tactile feature would not cause a major disruption to the general population because the notes will not appear substantially different from their current form.

BEP noted that the selection of the raised tactile feature will require additional targeted research, testing, and consideration of the public comments. Nonetheless, the significant benefits of notes with a tactile feature, including the excellent accuracy results the blind and visually impaired achieved with them, the ease of use evidenced both by the usability tests and applicable scientific research, and the relatively minimal impact on the general U.S. population, supports the inclusion of a raised tactile feature as a recommended accommodation despite its challenges. Based on experience, independent research, and the study, BEP believes it can develop a raised tactile feature that is durable and can be incorporated into its existing manufacturing systems at a reasonable cost, coincident with the introduction of the next design series of U.S. currency.

BEP invites comment on its proposal to incorporate raised tactile features in the next redesign of its currency.

II. Large, High-Contrast Numerals: BEP began incorporating large, high-contrast numerals into Federal Reserve notes beginning with the Series 1996 design $50 note in October 1997. In March 2008, BEP increased the size of the large high-contrast numeral with the introduction of the Series 2006 $5 note. The feedback received from visually impaired individuals has been positive. This feature will be continued in the new-design $100 note, which is the last in the Series 2004 family of designs. Because BEP has experience printing this feature and the visually impaired community has provided positive feedback on it, BEP proposes to continue using this feature in the next design for U.S. currency. BEP is aware, however, that there may be a number of options concerning the size, color, placement, background contrast and other features for these large numerals that may improve accessibility of currency for people with low vision. BEP invites comment from the public, including people with low vision, about the best choices for the proposed large, high-contrast numerals.

III. Supplemental Currency Reader Program: BEP will establish a supplemental currency reader distribution program. The purpose of the program is to provide blind and visually impaired people a means that can be used independently to correctly identify the denomination of U.S. currency. In compliance with legal requirements, BEP will loan a currency reader device to all blind and visually impaired U.S. citizens and legal residents who wish to avail themselves of this program. The individual may borrow the reader for as long as the individual desires the assistance of the reader. Before a reader is distributed, BEP first will verify that the requestor is eligible.

Under the reader program, individuals who are United States citizens or people legally residing in the United States who are blind or visually impaired and who need a reader to accurately identify the denomination of U.S. currency will be able to obtain a reader at no cost to the individual. BEP will define blind or visually impaired under the same definition as the study, with the following change to the study's definition of visual impairment: The reader program will not extend to visually impaired individuals whose impairment is corrected with ordinary eyeglasses or contact lenses.

BEP is considering the scope of an appropriate verification framework to determine eligibility to receive a reader. Specifically, it is considering a framework inspired by the eligibility requirements that the Library of Congress uses when loaning library materials to blind and other disabled persons as set forth in 36 CFR 701.6. Under that framework, applicants may submit verification of their eligibility from a "competent authority." BEP would define a "competent authority" as one of the following: doctors of medicine, doctors of osteopathy, doctors of optometry, registered nurses, and licensed practical nurses.

Alternatively, if a person who is blind or visually impaired has verification of visual impairment from another federal agency, including the Social Security Administration, the Library of Congress, or a state or local agency, that person need only submit a copy of that verification. BEP is inviting comments on whether this verification system is appropriate, or whether other frameworks would be more appropriate. Parents or legal guardians of a blind or visually impaired child under 18, and caregivers, legal guardians, or those with power of attorney for a U.S. citizen or someone legally residing in the U.S. may act as a proxy on behalf of the blind or visually impaired child or represented individual and request a currency reader. BEP will require verification for the child or represented individual.

BEP will solicit and award a single, long-term contract to implement the currency reader program. The contractor will be designated as the Currency Reader Program Coordinator (CRPC). Once the program is operational, a potentially eligible person may request a currency reader by contacting the CRPC and completing and submitting a request form. Depending on the verification framework adopted, upon verification of eligibility, the person will be provided a reader.

BEP is seeking answers to the following questions.

1. What would be the ideal placement of the raised tactile feature? In what kind of pattern or patterns should the raised tactile feature be arranged?

2. How should the large, high-contrast numerals be incorporated? In other words, what colors should BEP use, what is the optimal size of the numerals, and where should the numerals be placed on the note?

3. What background colors would provide the highest color contrast for people who are visually impaired?

4. What technological solutions should BEP explore to help people who are blind and visually impaired denominate currency?

5. What is the nature of the burden, if any, on the general public of including a raised tactile feature on U.S. currency?

6. If there are any burdens imposed on the public by a raised tactile feature on currency, how can such burdens be minimized?

7. What is the nature of the burden, if any, on industry and business of including a raised tactile feature on U.S. currency?

8. If there are such burdens, how can they be minimized?

9. Does the supplemental currency reader program impose a burden on the blind and visually impaired?

10. If so, what are those burdens, and how can they be minimized?

11. Does a verification process of the currency reader program inspired by the Library of Congress process impose too a great a burden on the blind and visually impaired?

12. If so, what are those burdens, and how can they be minimized?

13. Alternatively, if a person who is blind or visually impaired has verification of visual impairment from another federal agency (such as the Social Security Administration or Library of Congress), or a state or local agency, should BEP allow that person to submit a copy of that verification in order to satisfy a proof of visual impairment requirement in order to obtain a currency reader? If so, what burdens might this impose, and how can those burdens be minimized?

14. Should BEP consider working with local governments and/or state agencies to deliver the currency readers?

15. Should BEP consider additional or different criteria when determining eligibility for the currency reader program?

16. What administrative and/or operational challenges does the currency reader program create?

ACB will be filing comments, so readers should feel free to give us your input on these issues. For further information about how to file comments, or for a copy of the full proposal, contact Barbara LeMoine in the national office either by phone, (202) 467-5081, or by e-mail, [email protected].

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