Equivalent Facilitation Is Ableist

70s style header replicating the post title

I’ve been noodling on the idea of “equivalent facilitation” [EF]. Regulatory definition below but, in short, a specific thing needn’t be accessible of there exists something else that is and provides access to the same thing. So, a front door doesn’t need a wheelchair ramp if there’s a side entrance to the same building that does. In the case of technology and example would be screen readers users can get the same information from a table when a graph isn’t directly accessible.

I’ll talk mostly about screen readers below but understand this is about access and not about screen readers and software.

Equivalent Facilitation Is Ableist.

Definition

From Section 508 of the ADA 36 CFR appendix A§ E101.2
Equivalent Facilitation: The use of an alternative design or technology that results in substantially equivalent or greater accessibility and usability by individuals with disabilities than would be provided by conformance to one or more of the requirements in Chapters 4 and 5 of the Revised 508 Standards is permitted. The functional performance criteria in Chapter 3 shall be used to determine whether substantially equivalent or greater accessibility and usability is provided to individuals with disabilities.

I like definitions. My world works better in words so I use them a lot in writing.

Here’s an example of a feature for my own job. Genetic and family relationships can be organized in a tree-like structure called a Pedigree:

Caption: a family tree showing three generations that includes visual indications of related traits passed between each generation

Aside from showing a person’s family, one of the cool things in Pedigrees is a semi-standardized visual notation that allows for rapid review and search for specific traits across a family tree. From there, you can understand heritability of certain things and, if in a medical context, potentially help understand the symptoms stemming from a genetic anomaly.

Reference: Duke University standard pedigree symbols - PDF

It’s freaking cool. If you can see.

But What If I Can’t?

At my job, we have a process that allows various stakeholders to apply for an equivalent facilitation override on a project where the nature of it either cannot be readily made accessible, in some particular accessibility mode, or there are equivalent functions in the software that can stand in for it.

All the information available in the Pedigree is available in a separate activity that is accessible to screen readers. So what we did for this was redirect screen reader sets to the more accessible version of the data. That version was, essentially, a table that included all the same information

Good, right? Everyone gets what they need?

When you tell a person that they can do the thing, they just need to go elsewhere to do it, it creates two separate spaces and states for people. “Separate but equal”. But is it really equal?

Separate, but Unequal

Noted above, the visuals of the Pedigree can greatly increase a user’s ability to track traits across families. The data appearing in the Pedigree is often easy to structure in tables - a row is a family member, a column is a trait or other descriptor for that member like parent or sibling.

Tables are well understood concepts. They’ve been around for a while so most screen readers know how to handle them and, subsequently, most screen reader users do as well. So presenting a user with a table does, in fact, grant them access to the specific facts held within relatively quickly. For example, screen reader users can read the full row or columns contents from current selection, the row or column contents up to the current cell, the content from the current cell to the end of the row or column.

Pretty much anything listed in those linear dimensions can be quickly noted. But is that equal to the tree? How would a screen reader user trace a trait across families quickly? How would they swap focusable traits?

It may be accessible, but it damn well isn’t equivalent.

So Wtf Is Equivalent Then?

No one knows.

(One of) the problem with EF is that it was written primarily for physical access to locations and not technology. Literal, physical access to services. Because, once you’re in the building, there would be no more barriers to access, yes?

Lol, hardly, but that’s the underlying assumption with EF. Once you’re in the building, everything is peachy. It’s missing the trees for the forest. And further, equivalent facilitation provides no method for evaluating the equivalence. How do we even begin to create an equivalent experience if there’s no rubric?

Making a Pedigree accessible and making an accessible experience equivalent to the new one is tough. It requires designers to understand both what it is they are creating that offers the innovating experience for the new tool but also the way to offer those same innovations to users with low or no vision.

Are there ways to do that? Absolutely. Any problem can be solved.
Is it easy? NO.

But… The goal here is not to talk about what it would make to create an accessible version of a Pedigree. We can do that later - it’s a really engaging design problem. What matters is that “equivalent facilitation” creates two worlds. One world with the glitz glamor of new features and one world of flat data tables and no innovation. No one knows how to make that glamor translate to the accessible experience.

Equivalent facilitation creates a separate but equal world for people with disabilities even when it was supposed to offer the same level of service. But that’s not where we get, practically, when all the incentives in the world are stacked against doing the hard work of making the new thing accessible, of making the front stairs.

Published on August 18, 2023