A r c h i v e d  I n f o r m a t i o n Report on the Section 504 Self-Evaluation - May 1996

Office of the General Counsel

Overview

The Office of the General Counsel (OGC) is responsible for providing legal advice and services to the Secretary and to all Department offices on a wide variety of issues, including elementary, secondary, postsecondary, adult vocational and special education, business and administrative law, civil rights and educational access, and legislation. OGC also manages the Department's regulatory functions and ethics program and often represents the Department in litigation.

OGC provides mandatory ethics training for all Department employees. Approximately 50 training classes are held each year. OGC also provides training upon request from Department employees and those of other agencies, on the development and drafting of regulatory documents, including style, format and legal requirements.

The office is located in Federal Office Building 10B in Washington, D.C.

OGC Evaluation: Program Accessibility

There are no circumstances which would restrict or exclude persons with disabilities from participating in programs of the Office. Staff are aware that program policies or practices should be modified to enable persons with disabilities to participate in programs of the Office. The public is informed that program modifications will be made upon request.

OGC provides necessary equipment for employees with disabilities on an as needed basis. For example, a special computer was provided for an attorney who is blind and a telephone with an enhanced ringer has been provided for an attorney with a hearing impairment. Arrangements for all such equipment requests are made through the Operations Management Staff of OGC.

OGC has not received many calls from individuals with a hearing impairment and does not have its own TTY equipment. When OGC has received a call, the call has been routed through the FIRS. When necessary, OGC staff will use TTY equipment available within the Department (and listed in the Department's telephone directory) to communicate with an individual needing such assistance.

When OGC arranges a meeting, training session, or other activity, OGC staff will ask the scheduled participants if special assistance is needed to participate in the activity and, if so, will accommodate the needs of the participant. This situation occurs primarily in planning ethics or regulations training sessions.

OGC has made and will continue to make accommodations for Department employees with special needs in the provision of its ethics training. For example, OGC arranges for interpreters, provides materials on disk, or provides one-on-one training, as requested. In notifying employees about the annual mandatory training classes, OGC requests each Executive Officer to advise the Office if there are employees in their offices with special needs. Notification in advance allows the training materials to be provided to employees in a form that is most useful to them. For example, some visually-impaired employees prefer to receive materials on disks rather than in Braille. When OGC is not notified in advance of an employee's needs, the office will attempt to accommodate the employees' needs during the class. For example, on-the-spot readers for blind employees have been provided, and arrangements have been made for them to obtain the materials in an accessible form.

To accommodate blind employees, disks containing the Standards of Conduct, other reference materials, and the hypothetical ethics questions to be used in the training have been prepared and distributed before the training session. OGC actively solicits feedback from participants in the training sessions, and has made a special effort to discuss accommodations with employees who are disabled. Employees who are provided materials in advance are told to prepare only one of the hypothetical questions. They will then be seated with the group that works on that question at the training session. This practice significantly reduces advance preparation. In addition, OGC will continue to explore ways to provide accommodations for employees with disabilities in the least burdensome way so that their participation in the training is as effective as it is for non-disabled employees.

OGC should implement its plan to produce a reference set of Ethics Training materials in Braille so that employees who are visually impaired can use the Brailled training materials during the training class.

OGC is also exploring, with the Office of Government Ethics, alternative methods to make its lengthy regulations and other materials used in training sessions available in Braille. OGC is concerned, however, that providing training materials on disks to employees may be more useful and more cost-effective than converting all of the materials into Braille.

Regulatory documents published in the Federal Register include a TTY number at the Department or a Federal Information Relay Service "800" number. OGC also uses the Internet to disseminate information about, and take public comment on, regulatory documents. This procedure enables visually disabled individuals to access information electronically.

OGC does not usually receive requests for special accommodations for participants in regulatory training because OGC is usually not the office with responsibility for setting up the training session. The sponsoring office or agency provides the facility and makes arrangements to accommodate the special needs of its employees. In discussions with the sponsoring office or agency, OGC will, however, inquire if there are participants with special needs and if accommodations have been made for their participation in the training.

Existing Auxiliary Aids and Services

Specific OGC Services

TTYs
Available from the Department

Audio Tapes
Available within the Principal Office

Readers
Available within the Principal Office

Verbal Description
Available within the Principal Office

Commonly Available Services

All Principal Offices have available the following auxiliary aids and services: Large Print, Sign Language, Interpreters, Paper and Pen, and the Federal Information Relay System (FIRS). This Principal Office recognized its ability to provide the following:
Sign Language Interpreters
Available from the Department

Computer Diskettes
Available within the Principal Office

Large Print
Available within the Principal Office

Federal Information Relay Service (FIRS)
Available from the Department

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