Requirements To Provide Alternative Formats

Under Title II of the Americans with Disabilities Act (ADA) of 1990 the City of Milwaukee is required to ensure “equally effective communication” and to provide “auxiliary aids and services” for qualified individuals with disabilities who seek to participate in or benefit from the services, programs or activities of the City. 

Overview

People who have vision, hearing, or speech disabilities (“communication disabilities”) use different ways to communicate. For example, people who are blind may give and receive information audibly rather than in writing and people who are deaf may give and receive information through writing or sign language rather than through speech.

Title II of the ADA requires that the City of Milwaukee communicate effectively with people who have communication disabilities. The goal is to ensure that communication with people with these disabilities is equally effective as communication with people without disabilities. The purpose of the effective communication rules is to ensure that the person with a vision, hearing, or speech disability can communicate with, receive information from, and convey information to, the covered entity.

• The City of Milwaukee must provide auxiliary aids and services when needed to communicate effectively with people who have communication disabilities.
• The key to communicating effectively is to consider the nature, length, complexity, and context of the communication and the person’s normal method(s) of communication.
• The rules apply to communicating with the person who is receiving the City of Milwaukee’s  goods or services as well as with that person’s parent, spouse, or companion in appropriate circumstances.

Auxiliary Aids and Services

The ADA uses the term “auxiliary aids and services” (“aids and services”) to refer to the ways to communicate with people who have communication disabilities.

• For people who are blind, have vision loss, or are deaf-blind, this includes providing a qualified reader; information in large print, Braille, or electronically for use with a computer screen-reading program; or an audio recording of printed information. A “qualified” reader means someone who is able to read effectively, accurately, and impartially, using any necessary specialized vocabulary.
   
• For people who are deaf, have hearing loss, or are deaf-blind, this includes providing a qualified notetaker; a qualified sign language interpreter, oral interpreter, cued-speech interpreter, or tactile interpreter; real-time captioning; written materials; or a printed script of a stock speech (such as given on a museum or historic house tour). A “qualified” interpreter means someone who is able to interpret effectively, accurately, and impartially, both receptively (i.e., understanding what the person with the disability is saying) and expressively (i.e., having the skill needed to convey information back to that person) using any necessary specialized vocabulary.
   
• For people who have speech disabilities, this may include providing a qualified speech-to-speech transliterator (a person trained to recognize unclear speech and repeat it clearly) , especially if the person will be speaking at length, such as giving testimony in court, or just taking more time to communicate with someone who uses a communication board. In some situations, keeping paper and pencil on hand so the person can write out words that staff cannot understand or simply allowing more time to communicate with someone who uses a communication board or device may provide effective communication. Staff should always listen attentively and not be afraid or embarrassed to ask the person to repeat a word or phrase they do not understand.

In addition, aids and services include a wide variety of technologies including:

• assistive listening systems and devices;
• open captioning, closed captioning, real-time captioning, and closed caption decoders and devices;
• telephone handset amplifiers, hearing-aid compatible telephones, text telephones (TTYs) , videophones, captioned telephones, and other voice, text, and video-based telecommunications products;
• videotext displays;
• screen reader software, magnification software, and optical readers;
• video description and secondary auditory programming (SAP) devices that pick up video-described audio feeds for television programs;
• accessibility features in electronic documents and other electronic and information technology that is accessible (either independently or through assistive technology such as screen readers).

Real-time captioning (also known as computer-assisted real-time transcription, or CART) is a service similar to court reporting in which a transcriber types what is being said at a meeting or event into a computer that projects the words onto a screen. This service, which can be provided on-site or remotely, is particularly useful for people who are deaf or have hearing loss but do not use sign language.

The free nationwide telecommunications relay service (TRS), reached by calling 7-1-1, uses communications assistants (also called CAs or relay operators) who serve as intermediaries between people who have hearing or speech disabilities who use a text telephone (TTY) or text messaging and people who use standard voice telephones. The communications assistant tells the telephone user what the other party is typing and types to tell the other party what the telephone user is saying. TRS also provides speech-to-speech transliteration for callers who have speech disabilities.

Video relay service (VRS) is a free, subscriber-based service for people who use sign language and have videophones, smart phones, or computers with video communication capabilities. For outgoing calls, the subscriber contacts the VRS interpreter, who places the call and serves as an intermediary between the subscriber and a person who uses a standard voice telephone. The interpreter tells the telephone user what the subscriber is signing and signs to the subscriber what the telephone user is saying.

Video remote interpreting (VRI) is a fee-based service that uses video conferencing technology to access an off-site interpreter to provide real-time sign language or oral interpreting services for conversations between hearing people and people who are deaf or have hearing loss. The new regulations give covered entities the choice of using VRI or on-site interpreters in situations where either would be effective. VRI can be especially useful in rural areas where on-site interpreters may be difficult to obtain.

Additionally, there may be some cost advantages in using VRI in certain circumstances. However, VRI will not be effective in all circumstances. For example, it will not be effective if the person who needs the interpreter has difficulty seeing the screen (either because of vision loss or because he or she cannot be properly positioned to see the screen, because of an injury or other condition). In these circumstances, an on-site interpreter may be required.

If VRI is chosen, all of the following specific performance standards must be met:

• real-time, full-motion video and audio over a dedicated high-speed, wide-bandwidth video connection or wireless connection that delivers high-quality video images that do not produce lags, choppy, blurry, or grainy images, or irregular pauses in communication;
   
• a sharply delineated image that is large enough to display the interpreter’s face, arms, hands, and fingers, and the face, arms, hands, and fingers of the person using sign language, regardless of his or her body position;
   
• a clear, audible transmission of voices; and adequate staff training to ensure quick set-up and proper operation.

Effective Communication Provisions

The City of Milwaukee must provide aids and services when needed to communicate effectively with people who have communication disabilities.

The key to deciding what aid or service is needed to communicate effectively is to consider the nature, length, complexity, and context of the communication as well as the person’s normal method(s) of communication.

A person’s method(s) of communication are also key. For example, sign language interpreters are effective only for people who use sign language. Other methods of communication, such as those described above, are needed for people who may have lost their hearing later in life and do not use sign language. Similarly, Braille is effective only for people who read Braille. Other methods are needed for people with vision disabilities who do not read Braille, such as providing accessible electronic text documents, forms, etc., that can be accessed by the person’s screen reader program.

The City of Milwaukee is also required to accept telephone calls placed through TRS and VRS, and staff who answer the telephone must treat relay calls just like other calls. The communications assistant will explain how the system works if necessary.

Remember, the purpose of the effective communication rules is to ensure that the person with a communication disability can receive information from, and convey information to, the covered entity.

Companion

There may be an occasion where the City of Milwaukee may be communicating with someone other than the person who is receiving their goods or services. For example, Milwaukee Health Department staff may talk to a patient’s spouse, other relative, or friend about the patient’s condition or prognosis. The rules refer to such people as “companions” and require the City of Milwaukee to provide effective communication for companions who have communication disabilities.

The term “companion” includes any family member, friend, or associate of a person seeking or receiving an entity’s goods or services who is an appropriate person with whom the entity should communicate.

Use of Accompanying Adult or Children as Interpreters

Historically, the City of Milwaukee would have expected a person who uses sign language to bring a family member or friend to interpret for him or her. These people often lacked the impartiality and specialized vocabulary needed to interpret effectively and accurately. It was particularly problematic to use people’s children as interpreters.

The ADA places responsibility for providing effective communication, including the use of interpreters, directly on the City of Milwaukee. They cannot require a person to bring someone to interpret for him or her. The City of Milwaukee can rely on a companion to interpret in only two situations.

(1) In an emergency involving an imminent threat to the safety or welfare of an individual or the public, an adult or minor child accompanying a person who uses sign language may be relied upon to interpret or facilitate communication only when a qualified interpreter is not available.

(2) In situations not involving an imminent threat, an adult accompanying someone who uses sign language may be relied upon to interpret or facilitate communication when a) the individual requests this, b) the accompanying adult agrees, and c) reliance on the accompanying adult is appropriate under the circumstances. This exception does not apply to minor children.

Even under exception (2) , the City of Milwaukee may not rely on an accompanying adult to interpret when there is reason to doubt the person’s impartiality or effectiveness. For example:

• It would be inappropriate to rely on a companion to interpret who feels conflicted about communicating bad news to the person or has a personal stake in the outcome of a situation.
• When responding to a call alleging spousal abuse, police should never rely on one spouse to interpret for the other spouse.

Who Decides Which Aid or Service is needed?

When choosing an aid or service, the City of Milwaukee is required to give primary consideration to the choice of aid or service requested by the person who has a communication disability. The City of Milwaukee must honor the person’s choice, unless it can demonstrate that another equally effective means of communication is available, or that the use of the means chosen would result in a fundamental alteration or in an undue burden.  If the choice expressed by the person with a disability would result in an undue burden or a fundamental alteration, the City of Milwaukee still has an obligation to provide an alternative aid or service that provides effective communication if one is available.

Limitations

The City of Milwaukee is required to provide aids and services unless doing so would result in an “undue burden,” which is defined as significant difficulty or expense. If a particular aid or service would result in an undue burden, the entity must provide another effective aid or service, if possible, that would not result in an undue burden. Determining what constitutes an undue burden will vary from entity to entity and sometimes from one year to the next. The impact of changing economic conditions on the resources available to an entity may also be taken into consideration in making this determination.

In determining whether a particular aid or service would result in undue financial and administrative burdens, the City of Milwaukee departments should take into consideration the cost of the particular aid or service in light of all resources available to fund the program, service, or activity and the effect on other expenses or operations. The decision that a particular aid or service would result in an undue burden must be made by a high level official, no lower than a Department head, and must include a written statement of the reasons for reaching that conclusion.

Additionally, the City of Milwaukee is not required to provide any particular aid or service in those rare circumstances where it would fundamentally alter the nature of the goods or services they provide to the public. In the performing arts, for example, slowing down the action on stage in order to describe the action for patrons who are blind or have vision loss may fundamentally alter the nature of a play or dance performance.

Procedures Fulfilling Requests for Alternative Formats

Alternative Formats and Accommodation Statements

City of Milwaukee departments, divisions, offices, programs, etc. shall use the following example of alternative format accommodation statement and shall use the statement where applicable, including but not limited to; newsletters and publications, meeting agendas, public meetings/hearing flyers, etc.

This material is available in alternative formats for individuals with disabilities upon request. Please contact:
Jason Ostrowski, ADA Coordinator
City of Milwaukee
Department of Administration
Office of Equity and Inclusion
200 East Wells Street, Room 603
Milwaukee, WI 53202

Phone: (414) 286-3475
TTY: 711
Fax: (414) 286-5475
Email: [email protected]

Provide a 72 hour advance notice to ensure accommodation of request. Notices may include department, division, office or program contact information. 

ADA Coordinator and Department/Program Contacts

The City of Milwaukee ADA Coordinator should be the fixed point for receiving requests of accessible services for persons who are blind, deaf, deaf/blind and hearing impaired. City of Milwaukee Department/Program contacts shall work with the ADA Coordinator to ensure that their programs, services, employment, meetings, public hearings, etc. are accessible. 

Logging Requests for Alternative Formats and/or Accommodation

All requests will need to be logged into the online Request for Reasonable Accommodation or Modification form for recording purposes. An individual with a disability or their companion may also complete their request on-line.  Any phone calls to the ADA Coordinator and/or the department, division, office or program contact person must be logged into the on-line Request for Reasonable Accommodation or Modification form.  The ADA Coordinator will forward all requests to department, division, office or program contacts to coordinate the accommodation.

Appointments (Meetings, Hearings, etc.)

The City of Milwaukee departments, divisions, offices, programs, etc. that need a sign language interpreter for a meeting, training, public meeting/ hearing, etc. should notify the City of Milwaukee ADA Coordinator or appropriate contact person as soon as the need is known. It is important that individuals requesting a sign language interpreter provide at least 72 hours in advance of the meeting, if possible.  The City cannot guarantee an accommodation for a sign language interpreter if there is less than a 72 hour advance notice. Interpreters can be requested by using the on-line Reasonable Accommodation or Modification form.

Sources for Interpretive Services

Inclusion in this resource list does not constitute endorsement by the City of Milwaukee, nor does omission imply non-endorsement. Our goal is to provide you with information on some key resources available. Please let us know if you’re aware of a useful resource missing from this list.

CommunicationLink
10243 W. National Ave.
West Allis, WI
414-604-7231

Professional Interpreting Enterprise, Inc.
6510 W. Layton Ave., Ste. 3
Greenfield, WI
414-282-8115

More than Words Interpreting
500 W. Silver Spring Dr., Ste K200 Glendale, WI
414-581-4557

Interpreting Solutions Inc
540 S First St.
Milwaukee, WI
414-226-8191

Southern Wisconsin Interpreting and Translation Services, LTD
P.O. Box 196
Delavan, WI 53115
262-740-2590

Assistive Listening Devices

City of Milwaukee departments, divisions, offices, programs that need an assistive listening device can contact the ADA Coordinator (414-286-3475) to arrange for the use of one of City’s devices.

Alternative Format of Printed Materials

Print materials (such as meeting notices, agendas, reports, departmental brochures,etc. should contain a statement to inform individuals that alternative formats are available upon request for people with disabilities. Below is appropriate language for the notification, the notification should contain information about who to contact to receive accommodations. 

This material is available in alternative formats for individuals with disabilities upon request. Please contact:
Jason Ostrowski, ADA Coordinator
City of Milwaukee
Department of Administration
Office of Equity and Inclusion
200 East Wells Street, Room 603
Milwaukee, WI 53202

Phone: (414) 286-3475
TTY: 711
Fax: (414) 286-5475
Email: [email protected]

Provide a 72 hour advance notice, 7 days for Braille, to ensure accommodation of request. Notices may also include department, division, office or program contact information. 

The notification sentence should be in a sans serif font, such as Ariel or Helvetica 14-18 point font so individuals who may need an alternative format (large print) will be able to read that it is available.  Also, there are symbols that can help advertise there are available alternative formats. Departments, divisions, offices, and programs are encouraged to place these symbols next to the relevant information in your publications such as program brochures, application forms, event flyers, public meeting or hearing notices, etc.

Here are symbols that denote alternative format access:

Large print version available	Braille version available

Large Print Format

If an individual with a disability requests materials that are provided by a City of Milwaukee department, division, office, program to be in large print format the department, division, office, program is expected to generate that document/material within their own operations. Large print format is one of the easier alternative formats to provide if the document was produced by one of the common word processing programs (e.g., Word or WordPerfect). When an individual requests a document in large print, ask if there is a preferred font style and/or font size because individual needs vary.  One person may request the document in Univers 14-point font, while another may request Arial 18-point bold font.  As a default, either Arial or Helvetica font style sized 16- or 18-point should be used. After changing the font, some reformatting may be required; sometimes making a large print version “throws off” a document, just as changing margins can. If the document is produced in PDF format or by publishing software such as PageMaker, it may take more time, as conversion to a more easily manipulated document may be required.

Electronic Format or Email

Providing documents in electronic format or email is an easily accomplished alternative format, particularly if the document was produced by one of the common word processing programs (e.g., Word or WordPerfect). Verify the type of file in which the individual would like the document formatted. Ensure the type of document provided is compatible with the individual’s software. Keep in mind that headers and footers as well as materials in PDF format are not readable by audible screen readers. Sometimes, simply saving a copy of the original document onto a disk will fulfill the individual’s request. For additional information about converting word processing or PDF documents to screen-readable text documents, please contact ITMD.

Braille

The City of Milwaukee does not have in-house Braille services and any documentation requested in Braille format would require more to time to accommodate.  Therefore, the City requires a 7 day advance notice to provide documents in Braille format.

If the document is fairly short and straightforward, the document in Brailled format may be produced within a few days.  If the document is longer and/or complex, confirm delivery date with the vendor to insure accommodation may be provided within the request time period.  If the information is already a Word, WordPerfect, or text file document, you can simply e-mail the document to the Braille vendor.  If the document is in PageMaker or other “publisher” software, you will need to convert it to an acceptable type of file prior to sending it to the vendor.  If it is some other type of document, contact the vendor to verify what is needed to provide for them to do the Brailling.

Sources for Brailling & audio cassettes

Inclusion in this resource list does not constitute endorsement by the City of Milwaukee, nor does omission imply non-endorsement. Our goal is to provide you with information on some key resources available. Please let us know if you’re aware of a useful resource missing from this list.

Audio & Braille Literacy Enhancement (ABLE)
Central Library Building
803 West Wells Street
Milwaukee, WI  53233-1436
Phone: 414-286-3039
Email: [email protected]