UPDATE ON ACB'S CASE AGAINST THE TREASURY DEPARTMENT
by Melanie Brunson

Following the court rulings requiring the United States Treasury Department to make it possible for people who are blind to independently identify the denominations of their own money, the Bureau of Engraving and Printing in the Treasury Department contracted with a company called ARINC Engineering Services, LLC to explore the options that could be used to make U.S. paper currency more accessible. ARINC conducted focus group meetings at conventions of both ACB and NFB, and interviewed blind and visually impaired people of all ages from across the country. They have now issued a report to the Bureau of Engraving and Printing in which they outlined their findings. The report has been made public, and is almost 200 pages long. Although we wont be able to print it in its entirety, we have decided to put its executive summary in "The Braille Forum," as it provides a summary of the contractors findings and describes the processes they went through in order to arrive at their conclusions. Due to space constraints, we are publishing the summary in two parts. Watch for part 2 in the November issue.

For now, we will not comment on the reports conclusions. We will simply share its summary with you. We will most likely have more to say as the government moves forward with its response to the report. If you are interested in reading the report in its entirety, it is available online at http://www.bep.treas.gov/section.cfm/4/649.

EXECUTIVE SUMMARY

The Bureau of Engraving and Printing (BEP), a bureau within the United States (U.S.) Department of the Treasury, is responsible for designing and producing the U.S. Federal Reserve notes (hereafter referred to as U.S. currency). The BEP initiated this study to examine various aspects of the use of U.S. currency by the blind and visually impaired (VI) population of the U.S. The data, research, and analysis presented in this study will be used to evaluate potential measures that may enhance or improve the ability of the blind and VI to identify currency denominations.

Many factors impact the BEP's flexibility in modifying U.S. currency. The BEP must balance printing efficiency, counterfeit deterrence features, statutory requirements, and general banknote aesthetics when it determines a banknote's design to better serve the needs of those who are blind or visually impaired. All of these factors play a vital role in currency design. While this study does not make recommendations, it does provide data regarding future design of U.S. currency that will be useful to the BEP in making such recommendations in the future. The BEP has engaged ARINC Engineering Services, LLC, hereafter referred to as ARINC, to conduct a study addressing options for improving the ability of the blind and VI community to denominate (1) U.S. currency. For purposes of this study, ARINC established an ARINC team to perform this study through subcontracts with Battelle Memorial Institute, Naois LLC, and the University of Maine. Of note, all ARINC team members are independent from any security paper industry producers and original equipment manufacturers, including hand-held electronic readers, currency raw material or equipment suppliers, or any BEP service providers.

(1) "Denominate" is defined as the ability to differentiate the various denominations of U.S. currency. Description of the Study

The ARINC team focused study efforts on currency user requirements and needs of blind and visually impaired people, balanced with the practical and economic implementation considerations of various features. The detailed tasks the ARINC team performed included the following:

Gathered and analyzed data on the demographic, statistical, and other aspects of the blind and VI population of the U.S.

Conducted focus group discussions and surveys to assess the needs of the U.S. blind and VI population with respect to identification of U.S. currency denominations.

Researched currency from countries that have implemented accommodations to meet the needs of the blind and VI to independently denominate currency.

Conducted one-on-one usability tests to determine how well available accessibility accommodations meet the needs of the blind and VI participants.

Performed cost and benefit analyses of a group of accommodations (selected by the BEP). The benefit analyses considered the relative effectiveness of the selected accommodations in assisting various segments of the blind and VI population. The cost analyses included operational and technical impacts, and costs to government and industry organizations that manufacture, process, or handle U.S. currency.

Adapted a decision model to facilitate comparison of currency-related accommodations for the blind and VI. The decision model criteria included provisions for a variety of considerations ranging from functionality of devices to how well the accommodation performs in key usability scenarios for an individual user.

Customized and updated the decision model to include the cost and subjective aspects of the alternative accommodations. Number of Blind and Visually Impaired

To determine the number of blind and VI people in the U.S., the ARINC team had to establish a common definition of blindness and visual impairment. The ARINC team found a wide variety of definitions of these terms, as well as a range of different methodologies for estimating the number of affected people. Because of that variation, data on the number of blind and VI people in the U.S. are not consistent. As a result of analyzing the different methodologies and definitions used in previous research, the ARINC team used the following definitions for this study:

Blind = people who have no useful vision for reading any amount of print.

Visually Impaired = people who have difficulty seeing but have some useful vision, defined for this study as being able to read some print (with or without corrective lenses).

Based on available population studies and using the established definitions, the ARINC team estimated that in 2008 there were 304,060 blind people and 4,067,309 VI people in the U.S. Based on U.S. government population growth estimates, the ARINC team projects that by 2020, there will be 340,547 blind people and 4,555,386 VI people in the U.S. Assessment of Needs

To determine the needs of the blind and VI, the ARINC team conducted focus group discussions (Section 3), surveys (Section 4), and usability testing (Section 6). The ARINC team conducted focus groups with blind and VI participants from multiple organizations and demographic groups. Open forum sessions were held at the National Federation of the Blind (NFB) and American Council of the Blind (ACB) 2008 annual conventions. There were 402 blind and VI participants in the survey; 249 individuals participated in the focus groups and usability tests.

Through the survey data and focus group discussions, the ARINC team uncovered a number of key currency usage scenarios that blind and VI people find problematic. These scenarios provided a framework for looking at the individual accommodations to see how well they might meet the needs of the blind and VI population. The three problematic scenarios most commonly identified by the study participants were: transactions with no other people in close proximity (such as in a taxi or at a small kiosk), transactions while in a line (people waiting), and conducting a quick inventory of wallet or purse.

Survey results indicate that 72 percent of all participants said that they would feel less vulnerable if currency were easier for them to use, 72 percent of all participants felt rushed during transactions, and 70 percent felt vulnerable using cash. Survey results also indicated that 62 percent of all participants gave someone incorrect denominations in a transaction in the past year, 60 percent indicated they would use currency more often if it was easier for them to use, 59 percent relied on someone at the point of sale to tell them what denominations they were receiving, and 36 percent of all participants received incorrect change in the past year (e.g., realized after they got home, or not until the next time they used their currency). Needs of Blind and Visually Impaired Participants

Usability testing and the survey data results confirm that most blind participants in this study desire a way to independently denominate U.S. currency. VI participants in the usability tests were able to correctly denominate most U.S. currency, with over 95 percent accuracy. VI participants in the usability tests and focus groups said that they preferred accommodations that would enable identification from an arms length away. For purposes of this study, the ARINC team defined arms length as approximately one meter. This was based on the National Research Council (NRC) report published in 1995, which noted that a reasonable distance was approximately one meter, which is roughly the distance from the eye to the checkout counter of a grocery store, enabling easy and rapid identification. (2) More than half (56 percent) of VI survey participants said they could detect the large purple numeral 5 easier on the newer $5 notes than the smaller green numeral on the older design, but only 17 percent of them could identify that note at an arms length distance. Based on the results of both the usability testing and surveys, the ARINC team concluded that the primary desire of the blind and VI is to have the ability to conduct transactions quickly and accurately without causing delay to others waiting in a line.

(2) National Research Council, 1995, Currency Features for Visually Impaired People. National Materials Advisory Board, NRC. Washington, D.C.: National Academy Press, ISBN 0-309-05194-0. Analysis of Potential Accommodations

In order to understand the practical implementation issues, the ARINC team conducted (1) international benchmarking activities with countries that have implemented accommodations for blind and VI people, (2) discussions with subject matter experts and scientists (e.g., tactile perception science and color vision impairment), and (3) discussions with individuals in manufacturing and commerce who would produce and handle modified notes. All of these sources helped identify the potential impacts of implementing new accommodations.

The results of these investigations, described in Section 5 of this report, were used to plan usability tests and to establish economic analysis parameters. Several foreign currencies with blind and VI accommodations, four sample currency features, three commercially available currency reader devices, and three prototype currency reader devices were included in the hands-on usability testing portions of the study. Each usability test was recorded via digital video to facilitate collection of speed and accuracy results for each accommodation. Blind and VI participants evaluated a range of accommodations, including changes to color, contrast, and visual design of notes; tactile features; notes of differing sizes for each denomination; and currency reader devices. Key Findings for Color, Contrast, and Design from Usability Test Results

Color, contrast, and note design features focus on improving note recognition by the VI population in an arms length transaction scenario. The VI participants in the usability tests demonstrated that high foreground/background contrast for the primary numeral saves them time because they did not have to search both sides of the note for a numeral. VI people in the study who said they had reduced color sensitivity noted that high contrast numbers (e.g., Canadian dollar) were most helpful in aiding them. Focus group participants indicated that having medium- or large-size numbers in the upper corners, such as used on the United Kingdom (UK) pound, helped them successfully take a quick inventory of note denominations in a wallet. Extreme differences in the location of features on notes across denominations (e.g., Swedish kronor) allowed VI participants to identify features from further away (up to arms length) than with currencies that have design items in the same location for all denominations. Key Findings for Note Size Variation

Feedback from focus groups and survey results indicated that both blind and VI participants believed that they would benefit from note size variation as a way to identify currency denominations. Fifty-two percent of all of the survey participants indicated that size differences would help them denominate currency. Blind participants in the focus groups were very receptive to the concept of size differences as a denomination method. For VI focus group participants, note size variation was considered to be a secondary denomination method to augment visible features.

Results of the usability testing, however, where participants examined a single note at a time without other notes for comparison, indicated that the different sized notes were neither the fastest nor the most accurate method to denominate currency. Size changes along two dimensions (length and width) resulted in higher average accuracy results in the usability test than changes in only the length dimension. Results for the UK pound (two-dimensional size variation) averaged 60 percent accuracy, versus average of 48 percent for the Australian dollar (one-dimensional size variation).

Proportional formats (having incremental increases in length and width) were moderately successful, but did not yield consistently good results. Irregular, or hybrid, size formats (e.g., the Swedish kronor) provided larger differences in length and width. These formats yielded better usability results as measured by accuracy and time to denominate. It is feasible that more practice and familiarity with a particular accommodation such as sizes could improve the usability of different sized notes.


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