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SECTION 504 SELF-EVALUATION WORKBOOK (National Endowment for the Arts)

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SECTION 504 SELF-EVALUATION WORKBOOK
Civil Rights Office
National Endowment for the Arts
400 7th Street, S.W.
Washington, DC 20506
OMB Number 3135-0101
Page 1
INTRODUCTION
This Program Evaluation Workbook (Workbook) is designed to assist the staff of Endowment
grant recipients in evaluating the current state of accessibility of their programs and activities to
disabled visitors and employees. More specifically, the Workbook is intended to assist
organizations in their efforts to: (a) comply with the Endowment's regulations implementing
Section 504 of the Rehabilitation Act of 1973, as amended, including the preparation of a
self-evaluation of all programs, activities, policies, and practices to determine areas of
noncompliance, and (b) better understand the relationship between 504 and the Americans with
Disabilities Act (ADA). The Workbook is also designed to be used in conjunction with DESIGN
FOR ACCESSIBILITY, A Cultural Administrator’s Handbook a how to guide for making arts
programs accessible to people with various disabilities. Please see the “Resource List” page of
this Workbook to obtain a copy. The Arts and 504 Handbook is no longer available.
The Workbook has been made available for users to fill out online and “Save As” a PDF
document. Please note: upon completion, the Workbook should be printed and filed.
The Workbook is a tool to help you evaluate your programs, activities, and facilities. It is the first
step in a process leading to a self-evaluation document (and transition plan, if needed). Based
on the information you compile, this Workbook could be utilized to satisfy a portion of the self-
evaluation requirements. Recipients are required to maintain a file of information gathered during
the self-evaluation/transition plan process and keep it for a three (3) year period. This information
must be made available to the public and the Endowment upon request.
Section 504 provides for equal opportunity to enter facilities and participate in programs and
activities. It does not require that every part of every facility or program be accessible. The
important considerations are that disabled people have the same opportunities in employment,
the same opportunities to enter and move around in facilities, the same opportunities to
communicate, and the same opportunities to participate in programs and activities as non-
disabled people. Further, it is important to offer employment, programs, and services in settings
that are integrated rather than to segregate disabled people with special programs.
Some of the questions in this workbook may not apply to your organization. However, if you find
yourself skipping a large number of questions, you may be misunderstanding the fundamental
mandate behind the Section 504 requirements. If so, please read Chapter 1 of DESIGN FOR
ACCESSIBILITY for an explanation of the purpose and meaning of the regulations.
The self-evaluation contained in this Workbook will help you to evaluate the degree of
accessibility of your programs, activities, and facilities so that you can plan full program
accessibility. Your self-evaluation must include a review of all functions of your organization.
Disabled individuals and/or organizations that represent disabled individuals should be included
in the self-evaluation process. The self-evaluation must include an examination of:
Page 2
• employment and personnel policies and practices;
• the extent to which programs and activities are readily accessible and usable by
persons with disabilities;
• the extent to which the delivery of benefits and services are free from discriminatory
effects on disabled persons; and
• the extent to which contractual arrangements are free from subjecting disabled
persons to discrimination.
RELATIONSHIP OF 504 TO ADA
The Americans with Disabilities Act (ADA) prohibits discrimination on the basis of disability in
employment (Title I), state and local government services (Title II), and places of public
accommodation and commercial facilities (Title III).
The ADA extends the requirements of 504 to all activities of state and local governments under
Title II, and under Title III, to "places of public accommodation" operated by private entities,
including places of "public display or collection" such as museums. Arts groups operated by state
or local governments, therefore, are covered by Title II of the ADA, while those operated by
private entities are covered by Title III. Both Titles II and III were effective on January 26, 1992.
Organizations operated by Federal Executive agencies are not affected by the ADA, but are
covered by the requirements of Section 504 and 501 for federally conducted programs and
activities.
The requirements of the ADA for places of public accommodation and state and local
governments are based on, and are essentially the same as, the requirements of Section 504.
The major difference is in the requirements relating to architectural barriers in existing facilities.
Under Title II, state and local government entities are covered by the same standard as is used
under Section 504 with respect to existing facilities. They must ensure that the services,
programs, and activities they offer are accessible to individuals with disabilities, but they may use
alternative methods for providing access.
Private organizations that operate places of public accommodation (i.e., entities that are not
state or local governments) are covered by Title III. In existing facilities, public accommodations
must remove barriers when removal is "readily achievable" -- that is, easily accomplishable and
able to be carried out without much difficulty or expense. What is "readily achievable" will be
determined on an individual, case-by-case, basis in light of the resources available. The case-by-
case approach takes into account the diversity of enterprises covered by Title III and the wide
variation in the economic health of particular entities at any given moment.
Public accommodations that are also recipients of federal financial assistance must comply with
the requirements of both Title III of the ADA and Section 504. Thus, under Title III, they must
remove architectural barriers if removal is readily achievable, even if it would be possible to
provide program access through alternative methods. And, if barrier removal is not readily
achievable, they must still comply with Section 504's requirement for provision of program
Page 3
access. Thus entities covered by both Title III of the ADA and Section 504 Rehabilitation Act
must comply with both laws. Compliance with Section 504 does not guarantee compliance with
the ADA.
The most rigorous physical accessibility requirements apply to new construction and alterations.
The Department of Justice's ADA regulations adopt specific architectural standards for new
construction and alterations. Places of public accommodation and commercial facilities covered
by Title III must comply with the Americans with Disabilities Act Accessibility Guidelines for
Buildings and Facilities (ADAAG). State and local governments may use either ADAAG or the
Uniform Federal Accessibility Standards (UFAS), which is the standard used under Section 504.
THE ENDOWMENT'S ENFORCEMENT OF SECTION 504
Recipients of Endowment funds are required to certify that their programs and activities are
and/or will be conducted in compliance with the Endowment's regulations implementing Section
504 and Title II of the Americans with Disabilities Act (ADA).
The National Endowment for the Arts takes the enforcement of Section 504 of the Rehabilitation
Act of 1973, as amended, and Title II of the Americans with Disabilities Act seriously. If the
Endowment discovers that a recipient is in noncompliance with the 504 Regulations and/or Title
II, the Endowment has authority to suspend and/or terminate funding.
SELF-EVALUATION CHECKLIST
I. General
This checklist is presented as a guide to identify physical barriers that might restrict access to
individuals with disabilities. Use of this particular checklist is not mandatory, but is provided to
assist grant recipients in completing the required self-evaluation of compliance with Section 504
of the Rehabilitation Act of 1973.
The following general list of disabilities should be considered, although it is not considered to be
all-inclusive:
• Visual Impairment
• Hearing Impairment
• Speech Impairment
• Coordination Disabilities
(impairments of muscle control resulting
in loss of faculty coordination)
• Mobility Impairment
• Emotional Psychological Disorders
• Learning Disabilities
• Life Threatening Diseases (HIV, AIDS
virus)
• Missing Limbs
Page 4
NOTE: One of the most effective approaches to examining service and program accessibility is
to conduct a "client path analysis." This analysis is simply a walk-through of the process needed
for a citizen to participate in a service you provide; for example, musical production. There are
two aspects to the analysis: (a) analysis of the physical path traveled, and (b) analysis of the
administrative requirements of the service delivery, (e.g., eligibility criteria, application
procedures).
II. Policies and Practices Concerning Employment for Qualified Disabled Persons
The following areas concerning employment should be examined, although it is not considered
to be all-inclusive:
A. Employment Practices and Policies
1. Employment Practices - applications, advertising, recruiting, pre-
employment inquiries, interviewing, physical examinations, testing, etc.
2. Personnel Policies position descriptions, statements of qualifications, job
classifications, salary schedules, work schedules, leave policies, fringe
benefits (medical/life insurance, retirement benefits), training, promotions,
layoffs and terminations, evaluations, collective bargaining agreements,
etc.
B. Reasonable accommodation for “qualified disabled individuals”
C. Effective grievance procedures
D. On-going employee seminars to promote understanding
III. Physical Accessibility to Facilities Used by the Public
The following list for facilities should be evaluated, although it is not considered to be all-
inclusive:
• Elevators
• Ramps
• Doors and Doorways
• Rest Rooms
• Water Fountain
• Identification (for room or offices)
• Switches and Controls (lights, heat, etc.)
• Hazards (manholes, protruding
or low-hanging objects
• Communication
● Parking Spaces
● Entrances
● Stairs
● Floors, Floor Coverings
● Public Telephones
● Lighting
● Emergency Signals
● Public Meeting Rooms
● Fire Exits
NOTE: Grantees are not necessarily required to make each existing facility or every part of
an existing facility accessible to and usable by disabled people. However, they must
ensure that their programs and activities, when viewed in their entirety, are accessible and
usable by disabled individuals.
Page 5
IV. Actual Self-Evaluation Workbook
Contained on the following pages is the actual self-evaluation workbook.
The questions in this self-evaluation workbook are cross-referenced to the
Endowment's 504 Regulations and to DESIGN FOR ACCESSIBILITY. The
appropriate sections of the Endowment's 504 Regulations are listed next to each
question in the right margin.
ALL OTHER REFERENCES ARE TO DESIGN FOR ACCESSIBILITY.
You may fill this workbook out electronically. If after or while completing this
workbook you have any questions or need copies of the Section 504 regulations,
please contact:
Civil Rights Office
National Endowment for the Arts 400 7th Street, S.W.
Washington, DC 20506
(202) 682-5454/voice
(202) 682-5695/TT
(202) 682-5553/fax
The Web site address for the Civil Rights Office of the National Endowment for the Arts is
https://www.arts.gov/about/civil-rights-office.
The Web site address for the National Endowment for the Arts is: www.arts.gov
BURDEN STATEMENT
The Office of Management and Budget requires federal agencies to supply information on the
time needed to complete forms and also to invite comment(s) on the paperwork burden. The
Endowment estimates the average time to complete this application is four (4) hours per
response. This estimate includes the time for reviewing instructions, researching, gathering,
and maintaining the information needed, and completing and reviewing the data. Please send
any comments regarding the estimated completion time or any other aspect of this evaluation,
including suggestions for reducing the time to complete, to the Civil Rights Office, National
Endowment for the Arts, Washington, DC 20506; and to the Office of Management and Budget,
Paperwork Reduction Project (3135-0101), Washington, DC 20503.
Page 6
I. DO YOU QUALIFY?
504 REGS SECTION
A.
When organizations make application to the Arts Endowment
for a grant, they certify that they will comply with certain federal
nondiscrimination laws including Section 504 of the
Rehabilitation Act of 1973, as amended. When so certifying, the
prospective grantee agrees to comply with the 504 Regulations
during the grant period with two exceptions. If any personal
property is acquired with federal assistance, this assurance
obligates the applicant for the period during which it retains
ownership or possession of the property. If any real property or
structure is improved with federal assistance, this assurance
obligates the applicant for as long as the property or structure is
used for the purpose for which it was acquired at the time the
grant was awarded or similar public purpose. Are you applying
for or have already received an Arts Endowment grant?
☐ Yes. Your organization qualifies and the 504 Regulations
apply to your organization. Go to question D.
☐No. Answer questions B and C to see if you qualify
otherwise.
1151.1, 1151.2, 1151.41
B.
Does your organization receive any funds from other federal
agencies or state arts agencies? See DESIGN FOR
ACCESSIBILITY, CHAPTER TWO, PAGE 26.
☐ Yes. List each project grant or contract through which you
receive federal or state money.
☐ No. If you receive no federal or state arts agency funds nor
any local or state funding subgranted f rom a federal source,
then the 504 Regulations may not apply, but the ADA might.
1151.3 (e) (f)
C. Is your organization supported by a local or state government
agency that receives federal funds?
☐Yes. Contact that agency's general counsel to determine to
what extent the 504 Regulations apply to your organization. List
any projects that are supported with this agency's funds:
☐No. If you answered no to both B and C, then the 504
Regulations do not apply to your organization. However, note
that ADA requirements may still be applicable.
1151.3 (e) (f)
D. Do you have a copy of the 504 Regulations from each federal
agency funding your organization?
☐
☐
Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER ONE,
PAGE 7 and CHAPTER TWO, PAGES 16-22
504 Regulations are available from the following sources:
1151.3 (e) (f)
Page 7
I. DO YOU QUALIFY?
504 REGS SECTION
Civil Rights Office
National Endowment for the Arts
400 7th Street, S.W.
Washington, DC 20506
https://www.arts.gov/about/civil-rights-office
Office of Civil Rights
Department of Health and Human Services
3300 Independence Avenue, S.W. Washington, DC 20201
http://www.hhs.gov/ocr/
U.S. Department of Justice
Civil Rights Division, Disability Rights Section
950 Pennsylvania Avenue, N.W.
Washington, DC 20530
https://www.justice.gov/crt/disability-rights-section
Page 8
II. ADMINISTRATIVE QUESTIONS 504 REGS SECTION
A. Self-Evaluation
1151.42
1. Has your organization conducted a 504 self-evaluation?
☐ Yes. See DESIGN FOR ACCESSIBILITY
CHAPTER TWO, PAGES 20-21.
☐ No. Assess your progress by answering the following
questions:
1151.42 (e)
2. Has a staff member been appointed as your organization's
504 coordinator?
Yes.
No. A 504 coordinator is not specifically required under
the Arts Endowment's 504 Regulations as a full-time
position, but it is recommended as at least a part-time
assignment. Ultimately, someone representing your
organization must sign a self-evaluation document and a
transition plan (if required) committing your organization to
accommodations for disabled visitors and staff. See
DESIGN FOR ACCESSIBILITY CHAPTER TWO, PAGES
20-21.
☐
1151.42 (a)(5)
1151.16 (d)
3. Have you undertaken to identify the disabled population and
organizations representing disabled people in the area you
serve? See DESIGN FOR ACCESSIBILITY, PAGE 30 (A
Person with a Disability definition).
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 23-25.
1151.11, 1151.12,
1151.17a) (6)
4. Does your state or local arts commission (agency) or arts
service organization have an advisory committee that may
assist you in evaluating your policies, programs, and other
activities?
☐ Yes.
No See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGE 25.
☐ .
Does your advisory body include disabled individuals to
advise and assist your efforts to ensure pr ogram
accessibility?
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGE 25.
The advisory body should contain at least one person who is
mobility impaired, one person who is hearing impaired, and
one visually impaired person, plus representatives from an
association of disabled citizens (or developmental
1151.17 (a)(6),
1151.42 (a)
☐
Page 9
II. ADMINISTRATIVE QUESTIONS
504 REGS SECTION
disabilities council), and representatives from the local
organizations serving disabled constituents.
5. Do you have any disabled staff members who would be
willing to serve on advisory committees for arts
organizations or as consultants in their area of expertise?
Yes. ☐
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGE 25.
1151.42a)(1),(2),(3)
6. Have you discussed overall architectural and program
accessibility with your disabled employees, and are they
participating in this survey?
Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER
ONE, PAGES 8-10 CHAPTER TWO, PAGES 25-27.
N/A
☐
☐
☐
1151.22 (a) (d),
1151.42 (a)(1),(2),(3)
7. If any structural accommodations are required, have you
prepared a transition plan?
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPGER
TWO, PAGE 21.
1151.22(b) (c) (d)
8. Have you evaluated your policies and practices?
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 23-30.
1151.42 (a)(1),
1151.16, 1151.17
9. Have you modified or planned to modify policies/practices
that are discriminatory?
Yes.
☐
☐
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 23-30.
1151.42 (a)(2),(3),
1151.22 (d)
10.Have you a completed, signed self-evaluation form on file?
Yes. ☐
Does it contain a list of:
a. the advisory committee?
☐Yes ☐No
b. a description of areas examined and problems
identified?
☐Yes ☐No
c. a description of proposed modifications?
☐Yes ☐No
1151.42(4)
Page 10
II. ADMINISTRATIVE QUESTIONS
504 REGS SECTION
☐
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 23-30.
11. Have you established a grievance procedure to negotiate
complaints with disabled people?
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGE 23-30.
1151.43
B. Employment
1151.31
1. 504 includes a nondiscrimination statute which requires an
organization not to discriminate ag ainst a disabled applicant
if he or she is qualified for the position. However, an
organization is not required to recruit disabled employees,
fill quotas, reallocate essential functions, or create a position
that does not exist.
Does your organization make its job application process and
public notices of employment accessible to people with
various disabilities?
☐ Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 17-19, and PAGES 29-30.
☐
1151.11, 1151.12,
1151.31, 1151.4(b)
2. Does your method of recruiting employees use appropriate
communications for hearing impaired, visually impaired, and
speech impaired people?
Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 29-30 and CHAPTER FIVE, PAGES 97-109.
☐
☐
1151.16d)
3. Both Section 504 and Title I of the ADA prohibit the use of
employment tests and other selection criteria that screen out
individuals with disabilities, unless the employer can
demonstrate certain designated factors. In addition, the A DA
generally prohibits medical examinations and inquiries about
the nature or severity of a disability. Are your policies in
compliance with these regulations?
Yes. ☐
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 17-19 and PAGES 29-30.
1151.33, 1151.34
4. Do recruitment materials contain a nondiscrimination policy?
[Note: A nondiscrimination policy should state that the
organization does not "discriminate on the basis of
disability...in admission or access to, or employment in, its
1151.4 (b)
Page 11
II. ADMINISTRATIVE QUESTIONS
504 REGS SECTION
programs and activities." See 504 Regulations Section
1151.4.]
Yes.
No.
☐
☐
5. Have you any employees, panelists, or board members with
disabilities at present?
Yes. List position(s).
☐
☐
No.
6. Have you employed any disabled people within the past 5
years?
☐ Yes. List position(s).
No. If you have answered no to questions 5 and 6, go to
question 8.
☐
7. If you have had disabled employees, have you made
reasonable accommodations—that is, modifications
to your facilities or to the job structure to accommodate the
employee(s)?
See DESIGN FOR ACCESSIBILITY CHAPTER TWO,
PAGES 29-32.
☐ Yes. Explain briefly what accommodations you have
made.
☐ No. Modifications were unnecessary. Provide a brief
explanation why unnecessary.
1151.32, 29 CFR
1630.2
8. Do your employment policies and practices discriminate
against disabled people in any of the following areas?
See 504 Regulations Section 1151.31(d) for a detailed
explanation of each category.
a. Recruitment
☐Yes ☐No
b. Hiring, promotion, termination, and rehiring
☐Yes ☐No
c. Rates of pay or compensation
☐Yes ☐No
d. Job classifications
☐Yes ☐No
e. Sick leave and other leave policies
☐Yes ☐No
f. Fringe benefits
☐Yes ☐No
g. Financial support for training
☐
Yes
☐
No
1151.31 (d)
II. ADMINISTRATIVE QUESTIONS 504 REGS SECTION
Page 12
h. Employer sponsored activities, including social or
recreational programs
☐Yes ☐No
C. Notice
1151.4
1. Are your organization's administration and board of directors
aware of 504 and its possible impact on programs and
activities?
Yes. ☐
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGE 28
1151.1, 1151.16
2. Has your organization made public notice in print, audio,
and visual media that its programs or activities do not
discriminate on the basis of disability in admission, access,
or employment?
☐ Yes. Did you address:
The public?
☐Yes ☐No
Employees?
☐Yes ☐No
Employee be nefit agreements?
☐Yes ☐No
Employment Agencies?
☐Yes ☐No
Organizations representing disabled people?
☐Yes ☐No
Collective bargaining organizations?
☐Yes ☐No
Professional Associations?
☐Yes ☐No
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 20-21.
1151.4(a)
3. Is the above notice in recruit materials or publications which
contain general information about your organization?
☐ Yes. Specify which:
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 29-30.
1151.4(b)
4. Do you emphasize that your programs and activities are
accessible to disabled visitors in your advertisements, press
releases, newsletters, and other publications?
1151.4(a)
II. ADMINISTRATIVE QUESTIONS 504 REGS SECTION
Page 13
☐
Yes.
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER
NINE, PAGES 155-160.
5. Do you advertise your programs and activities in multiple
media so that visually, speech, or hearing impaired people
can learn of your program independently?
☐
☐
Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 24-25.
1151.4 (a),
1151.16 (d)
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 14
A. General Program Accessibility
1151.16, 1151.17,
Are your programs and activities "when viewed in their entirety"
accessible to disabled people? That is, can a disabled person take
part in any of the activities associated with the program whether as a
staff person, volunteer, performer, audience member, artist, visitor,
client, or student?
☐ Yes. To determine if your organization is truly "program accessible,"
answer the following questions:
1. Does the organization regularly advertise
physical access to its events and services?
☐Yes ☐No
2. Does the organization regularly advertise
programmatic access to its events and services?
☐Yes ☐No
3. Is there a fee or charge to attend or join the
program? Explain.
☐Yes ☐No
4. Is there a fee or charge to use the facilities?
Explain. ☐Yes ☐No
5. Are there discounts available?
☐Yes ☐No
What are the di scount rates?
What is the policy?
6. Are there TTs (TDD/TTY)? See DESIGN FOR
ACCESSIBILITY CHAPTER FIVE, PAGE 107.
☐Yes ☐No
Is the number listed on the letterhead?
☐Yes ☐No
Is the number listed in promotion material?
☐Yes ☐No
Is the staff trained to use the TTs (TDD/TTY)?
☐Yes ☐No
How many staff are trained?
7. Are there sign interpreted
performances/tours/exhibits/ events?
☐Yes ☐No
How often are they offered?
8. Is there an interpreter available at all times?
☐Yes ☐No
9. Is there an interpreter available upon request?
☐Yes ☐No
10. Is spoken material available in print?
☐
Yes
☐
No
1151.21, 1151.22
1151.22a)
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 15
11. Are there assistive listening devices?
☐Yes ☐No
See DESIGN FOR ACCESSIBILITY, CHAPTER
FIVE, PAGES 102-104.
What type is it? (FM, infrared, or Loop)
12. Are there audio-narrated performances/
tours/exhibits/events?
☐Yes ☐No
How often are they offered?
13. Are audiovisual materials audio-narrated?
☐Yes ☐No
See DESIGN FOR ACCESSIBILITY, CHAPTER
FIVE, PAGES 98-99.
14. Are audiovisual materials captioned?
☐Yes ☐No
15. Is printed material available in large print?
☐Yes ☐No
16. Is printed material available on audiocassette
tape?
☐Yes ☐No
17. Is printed material available in Braille?
☐Yes ☐No
18. Does the organization have materials for
communicating with learning impaired or
developmentally disabled people?
☐Yes ☐No
See DESIGN FOR ACCESSIBILITY, CHAPTER
FIVE, PAGES 108-109.
☐Answer "no" here if 1 - 18 above is no.
B. Integrated Setting
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 16
1. Are programs and activities presented in the "most integrated
setting" appropriate to the needs of disabled people? That is,
do disabled people have the same opportunity to participate as
non-disabled, and are programs and activities designed to
include both disabled and non-disabled people? See DESIGN
FOR ACCESSIBILITY CHAPTER TWO, PAGES 23-29.
☐ Yes.
List programs and activities in which disabled people participate in an
integrated setting:
☐ No. See DESIGN FOR ACCESSIBILITY CHAPTER TWO, PAGES
23-29.
1151.16
1151.16 (e)
1151.17 (a),
1151.22 (b)
2. Do you currently sponsor programs or activities specifically for
disabled people?
☐ Yes List the types of programs you offer, the disabilities they
address, and the reason for having a "special" program.
Are these special programs offered only when there is no other
way for the activity to be made available to disabled people?
Yes.
No. Segregated or special activities for disabled pe ople are
not prohibited by 504 regulations. Special programs, however,
do not provide equal opportunity to all federally funded
programs in the most integrated setting.
☐
☐
☐ No.
1151.16b)
3. Are disabled people free to choose whether they participate in
the "special" program or in the regular program?
☐
☐
Yes.
No. See DESIGN FOR ACCESSIBILITY CHAPTER
TWO, PAGES 23-29
1151.17 (a) (b)
C. Program Evaluation
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 17
Chapter Six of DESIGN FOR ACCESSIBILITY
contains questions to help you evaluate the accessibility of different
arts programs. The following section refers to these questions. To
evaluate your program and activity, answer the questions in the pages
referred to in the charts below. The "facility" for your type of program
(e.g., visual, media) includes those architectural features or spaces
that are particularly associated with the program, such as galleries,
stages, or studios.
1151.42, 1151.22
1. Can a mobility impaired person participate in your programs
and/or activities as a staff person, performer, audience
member, visitor, or volunteer?
☐ Yes. Check yes if all answers below are yes
☐ No. Check no if any answer below is no
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
a. Is the facility accessible? See DESIGN FOR
ACCESSIBILITY CHAPTER SIX, PAGES 117-130.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the activities of the program accessible? See DESIGN
FOR ACCESSIBILITY CHAPTER SIX, PAGES 117-130.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐
Yes
☐
No
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 18
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
c. Are the products of the program usable by mobility
impaired people? See DESIGN FOR ACCESSIBILITY
CHAPTER SIX, PAGES 117-130.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
2. Can a visually impaired person participate in your programs
and/or activities as a staff person, performer, audience
member, visitor, or volunteer?
Yes. Check yes if all answers below are yes ☐
☐ No. Check no if any answer below is no
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
a. Is the facility accessible? See DESIGN FOR ACCESSIBILITY
CHAPTER SIX, PAGES 117-130, and DESIGN FOR
ACCESSIBILITY CHAPTER FIVE, PAGES 98-102.
Visual Arts
☐Yes ☐No
Performing Arts
☐
Yes
☐
No
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 19
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the activities of the program accessible? See DESIGN FOR
ACCESSIBILITY CHAPTER SIX, PAGES 117-130, and DESIGN
FOR ACCESSIBILITY CHAPTER FIVE, PAGES 98-102.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the products of the program usable by visually impaired people?
See DESIGN FOR ACCESSIBILITY CHAPTER SIX, PAGES 117-
130, and DESIGN FOR ACCESSIBILITY CHAPTER FIVE, PAGES
98-102.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
3. Can a hearing impaired person participate in your programs
and/or activities as a staff person, performer, audience
member, visitor, or volunteer?
☐
☐
☐
Yes. Check yes if all answers below are yes
No Check no if any answer below is no
Visual Arts
Yes
☐
No
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 20
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Is the facility accessible? See DESIGN FOR ACCESSIBILITY
CHAPTER SIX, PAGES 117-130, and DESIGN FOR
ACCESSIBILITY CHAPTER FIVE, PAGES 102-108.
Visual Arts
☐Yes ☐No
Performing Arts
☐ ☐Yes No
Literary Arts
☐ ☐Yes No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the activities of the program accessible? See DESIGN FOR
ACCESSIBILITY CHAPTER SIX, PAGES 117-130, and DESIGN
FOR ACCESSIBILITY CHAPTER FIVE, PAGES 102-108.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the products of the program usable by hearing impaired
people? See DESIGN FOR ACCESSIBILITY CHAPTER
SIX, PAGES 117-130, and DESIGN FOR ACCESSIBILITY
CHAPTER FIVE, PAGES 102-108.
Visual Arts
☐Yes ☐No
Performing Arts
☐
Yes
☐
No
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 21
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
4. Can a learning impaired person participate in your programs
and/or activities as a staff person, performer, audience
member, visitor, or volunteer?
☐ Yes. Check yes if all answers below are yes
☐ No. Check no if any answer below is no
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Is the facility accessible? See DESIGN FOR
ACCESSIBILITY CHAPTER SIX, PAGES 117-130, and
DESIGN FOR ACCESSIBILITY CHAPTER FIVE, PAGES
108-109.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the activities of the program accessible? See DESIGN FOR
ACCESSIBILITY CHAPTER SIX, PAGES 117-130, and DESIGN
FOR ACCESSIBILITY CHAPTER FIVE, PAGES 108-109.
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 22
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
Are the products of the program usable by people with learning
disabilities people? See DESIGN FOR ACCESSIBILITY CHAPTER
SIX, PAGES 117-130, and DESIGN FOR ACCESSIBILITY
CHAPTER FIVE, PAGES 108-109.
Visual Arts
☐Yes ☐No
Performing Arts
☐Yes ☐No
Literary Arts
☐Yes ☐No
Media Arts
☐Yes ☐No
Design Arts
☐Yes ☐No
D. Program Modification
The following questions suggest ways that currently inaccessible
programs and/or activities can be modified without extensive structural
1151.42 (a)(2),(3),(4).
1151.17 (d)
III. PROGRAM ACCESSIBILITY 504 REGS SECTION
Page 23
changes.
1. Have you relocated or rescheduled any programs and/or
activities to an existing accessible facility to make them
available to disabled people?
☐ Yes. List programs and location:
☐ No. Can you locate a facility that is accessible or modify one
to be accessible? See DESIGN FOR ACCESSIBILITY,
CHAPTER THREE, PAGES 59-61.
1151.22 (b),
1151.17 (d)
2. Have you provided auxiliary aids such as TTs (TDD or TTY),
audio tapes, or sign language interpreters to make your
programs and/or activities available to people with
communication impairments?
☐ Yes. Specify which:
No. See DESIGN FOR ACCESSIBILITY, CHAPTER FIVE, PAGES
98-109.
☐
1151.16c)
3. Have you provided adequate communications by presenting all
written and spoken materials in other ways, such as by
interpreter, in printed form, in Braille, on audio tape, or in large
print?
☐ Yes. Specify which:
☐ No. See DESIGN FOR ACCESSIBILITY, CHAPTER FIVE, PAGES
98-109.
1151.16d)
4. Have you held awareness training sessions or otherwise
sensitized your frontline staff (docents, guards, ushers,
receptionists, or box office staff) to the needs of disabled
people?
Yes. How and when? ☐
☐ No. See DESIGN FOR ACCESSIBILITY, CHAPTER EIGHT,
PAGES 147-151
5. Do you have disabled people serving as advisors for program
planning?
☐ Yes.
☐ No. See DESIGN FOR ACCESSIBILITY, CHAPTER TWO, PAGE
25.
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 24
Not all buildings and facilities need to be accessible, but those that
house accessible programs and activities must meet minimum
requirements for accessibility. In DESIGN FOR ACCESSIBILITY,
please read CHAPTER ONE, PAGES 19-20, and CHAPTER THREE,
PAGES 62-82.
Both this Program Evaluation Workbook and DESIGN FOR
ACCESSIBILITY divide architectural accessibility into two parts. One
is general building accessibility, which includes getting into a building,
moving around in it, and finding and using rest rooms and other
facilities. These and other general topics are presented in CHAPTER
THREE, PAGES 6 2-82. The questions for surveying existing facilities,
below, are directed at general building accessibility.
The other aspect of architectural accessibility includes those
architectural elements unique to particular arts programs or activities.
These unique features such as galleries or stages, are discussed in
CHAPTER SIX, PAGE 115. Evaluation questions for these special
elements are in the section on Program Evaluation on page 18 of this
Workbook.
1151.22, 1151.23
A. Existing Facilities
The following questions are intended evaluate the evaluate the
general accessibility of your existing buildings and facilities. They
are coordinated with the general architectural accessibility
information in Getting There. Please read each section before
answering the questions below. These questions are not
comprehensive and are intended only to provide a general picture
of the accessibility of your existing buildings and facilities. For more
detail, see the Uniform Federal Accessibility Standards (UFAS)
1984, which presents minimal federal guidelines on the design,
construction, and alteration of buildings to make them accessible to
disabled people. More information appears at 28 CFR part 36. For
free copies of UFAS and other access information, contact the:
Architectural and Transportation Barriers Compliance Board
Suite 1000
1331 F Street, N.W.
Washington, DC 20004-1111,
1-800-USA-ABLE (voice or TT).
http://www.access-board.gov/
1151.22
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 25
1. Accessible Route, page 62
Is there an accessible route connecting the building entrance to:
accessible parking spaces? ☐Yes ☐No
off-site parking? ☐Yes ☐No
passenger loading zones? ☐Yes ☐No
public sidewalks? ☐Yes ☐No
public transportation stops? ☐Yes ☐No
Does each accessible route meet the following requirements:
A continuous, level, stable, firm, and slip-resistant surface?
☐Yes ☐No
At least 36" wide?
☐Yes ☐No
No curbs, steps, stairs, or abrupt changes in level?
☐Yes ☐No
No objects that protrude dangerously into the path?
☐Yes ☐No
2. Parking, page 63-64
Are accessible parking spaces provided?
☐Yes.
Connected by an accessible route? (See question 1)?
How many spaces and what are the measurements?
☐
☐ No.
Is off-site accessible parking provided?
Yes ☐
Connected by an accessible route? (See question 1)?
How many spaces and what are the measurements?
☐
☐ No.
Are passenger loading zones provided?
Yes. ☐
Connected by an accessible route? (See question 1)?
No.
☐
☐
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 26
3. Entrances and Doors, pages 65-67
Does the building have a primary entrance that is accessible?
☐ Yes. Check yes if all answers below are yes
☐ No. Check no if any answer below is no
Is the approach to the entrance door an accessible route; that is, is
it free from any steps, stairs, or steep slopes? (See question 1.)
☐Yes ☐No
Is the entrance door a swing door that provides an opening that is
at least 32" wide?
☐Yes ☐No
Does it swing:
In? ☐Yes ☐No
Out? ☐Yes ☐No
If the only door is a revolving door, the entrance is not
accessible.
Is it maneuverable by mobility impaired individuals?
☐Yes ☐No
Is there enough clear space on both sides of the door?
☐Yes ☐No
Is there a five foot by five foot level and clear area on the pull side?
☐Yes ☐No
Do double door vestibules have at least four feet between the open
door and the swing of the next door?
☐Yes ☐No
Is the threshold less than 1/2" high?
☐Yes ☐No
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 27
4. Interior Circulation, pages 68-69
Do halls and corridors meet the requirements for an interior accessible
route?
☐ Yes. Check yes if all answers below are yes
No. Check no if any answer below is no ☐
Does each hall or corridor meet the following requirements:
A continuous, level, stable, firm, and slip-resistant surface? (Thick soft
carpet is not acceptable.)
☐Yes ☐No
At least 36" wide? (Furniture or vending machines cannot be placed in
the accessible route.)
☐Yes ☐No
No curbs, steps, stairs, or abrupt changes in level?
☐Yes ☐No
5. Vertical Circulation, pages 70-72
Do all levels containing programs and/or activities that are intended to
be accessible meet at least one of the following criteria?
Yes. Check yes if at least one answer is yes
No. Check no if any answer below is no
☐
☐
Is your facility on one level throughout?
☐Yes. Go to question 6. ☐No
Are all floors connected by an elevator or ramp?
Yes. Does at least one elevator or ramp
connecting all floors meet the following requirements:
☐
Call buttons centered at 42" above the floor?
☐Yes ☐No
Cab at least 30" x 48"?
☐Yes ☐No
Top button on control panel no more than 54" (parallel approach) or
48" (front approach) above the f loor?
☐Yes ☐No
Tactile labels for controls?
☐Yes ☐No
☐
No. Check no if any answer above was no.
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 28
Are all changes in level that are not connected by elevators connected
by accessible ramps or lifts?
☐
☐
Yes. Do ramps or lifts meet the requirements?
Yes. Specify the measurements:
☐No.
☐ No. Check no if answer above is no.
If some or all floors are connected by stairs only, are all the programs
and/or activities located on these floors also presented in other
locations where they are accessible to disabled people?
Yes. Specify alternative location:
No.
☐
☐
6. Water Fountain, page 74
Is at least one water fountain provided that is usable by disabled
people?
☐ Yes. Specify the measurements of the fountain:
☐ No.
7. Rest Rooms, pages 78-81
Is at least one accessible rest room provided?
Yes.
No.
☐
☐
Provide the measurements for the
following features:
Entrance door:
Clear floor space:
Height of toilet and urinals:
Width and length of the stall:
Width and length of the grab bars and their location in the stall:
Height of the toilet paper dispenser:
Height of the paper towel dispenser:
Height of sink:
Clear space between sink apron and floor:
Height of soap dispenser:
Height of mirror:
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 29
8. Telephones, page 74
Is at least one telephone provided that is usable by disabled people?
☐ Yes. Specify height of the highest operable part (e.g., coin slot of
the telephone):
☐No.
9. Signage, page 75
Are signs clear and readable with large letters that contrast with the
background?
☐ Yes.
☐ No.
10. Clear Floor Space and Work Surfaces, page 82
Do work surfaces, controls, and equipment have enough clear floor
space for people in wheelchairs to pull up close to the object?
☐ Yes. Specify measurement of clear floor space:
No. ☐
Where a person must pull up under the object, is there enough knee
clearance?
☐ Yes Specify height of knee clearance:
No. ☐
11. Reach Ranges, page 73
Are all controls and hardware mounted low enough to be within easy
reach of diminutive-size or seated people? Example: Light switches,
air conditioning controls, audio equipment controls.
☐ Yes Specify height of controls and hardware:
No. ☐
12. Controls and Hardware, page 73
Are controls and hardware easily operated? Example: Light switches,
air conditioning controls, audio equipment controls.
Yes ☐
☐ No.
IV. ARCHITECTURAL ACCESSIBILITY 504 REGS SECTION
Page 30
13. Warning Signals, page 75
Do emergency warning systems produce both audible and visible
signals?
Yes
No.
☐
☐
14. New Construction
Do new buildings and facilities meet the requirements of Uniform
Federal Accessibility Standards?
☐ Yes
☐ No. See DESIGN FOR
ACCESSIBILITY, CHAPTER THREE,
PAGE 55.
15. Theater, Concert Halls, Auditoriums, etc. pages 121-124
Are there existing wheelchair locations integrated throughout?
☐ Yes
How many?
Where are they located?
What are the measurements?
No. ☐
Are there accessible routes leading to the wheelchair locations?
☐ Yes. Describe.
No. ☐
Page 31
RESOURCE LIST
DESIGN FOR ACCESSIBILITY, National Endowment for the Arts
Available online at www.arts.gov/resources/Accessibility/pubs/DesignAccessibility.html
Uniform Federal Accessibility Standards, General Services Administration
Section 504 of the Rehabilitation Act of 1973, as amended.
https://www.govinfo.gov/app/details/CFR-2010-title45-
vol3/CFR-2010-title45-vol3-part1151
Civil Rights Office
National Endowment for the Arts
400 7th Street, S.W.
Washington, DC 20506
(202) 682-5454/voice; (202) 682-5695/TT
https://www.arts.gov/about/civil-rights-office
Office of Accessibility
National Endowment for the Arts
400 7th Street, S.W.
Washington, DC 20506
https://www.arts.gov/impact/accessibility
U.S. Department of Health & Human Services
Office of Civil Rights, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201
OCR Hotline/Voice: (1-800-368-1019)
www.hhs.gov/ocr
The Architectural and Transportation Barriers Compliance Board offers free copies of the
Uniform Federal Accessibility Standards (UFAS), Americans with Disabilities Act Accessibility
Guidelines (ADAAG) required under Title III (public accommodations), and other technical
assistance materials concerning architectural, transportation, and communications issues.
Architectural and Transportation Barriers Compliance Board
1331 F Street, N.W., Suite 1000
Washington, DC 20004-1111
(202) 272-0080/2253 - Voice
]202) 272-0082/2822 - TTY
(202) 272-0081 - Fax
www.access-board.gov
The Department of Justice is committed to ensuring that the ADA is implemented effectively,
and has established a program for providing technical assistance to organizations with
responsibilities under the law as well as individuals protected by it.
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, NW
Page 32
4CON, 9th Floor
Washington, DC 20530
https://www.justice.gov/crt/disability-
rights-section
Office Number
(202) 307-0663 (Voice and TDD)
Fax: (202) 307-1197
ADA Toll-Free Information Line
800-514-0301 (Voice)
800-514-0383 (TT)
The National Park Service provides technical assistance for program accessibility including
access to historic properties and museums.
https://www.nps.gov/aboutus/accessibility.htm
The National Center on Accessibility at Indiana University receives support through the
National Park Service to conduct research, develop resources, and conduct training on making
parks, including museums and historic sites, accessible to people with disabilities.
National Center on Accessibility
501 N. Morton Street Suite 101
Bloomington, IN 47404
Phone: 812-856-4422
nca@indiana.edu
https://ncaonline.org/
State Arts Agencies, a list of which can be found on the Endowment’s Website at
https://www.arts.gov/impact/accessibility/saa-rao-accessibility-coordinators
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