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Slide 1: ADA National Network Learning Session – FEMA’s Section 504 Disability Access Plan
•	Stephanie Fell, Federal Emergency Management Agency, Office of Equal Rights
•	December 12, 2019
•	Image: Logo of the Department of Homeland Security
•	Image: Logo of FEMA
Slide 2: Key Authorities
•	Section 504 of the Rehabilitation Act of 1973 (prohibits discrimination based on disability and requires equal access for people with disabilities)
•	Section 504 applies to FEMA’s programs and activities
•	Section 504 applies to recipients of federal financial assistance, e.g., entities that receive federal grants, including State, local, Tribal and Territorial emergency managers
•	Sections 308 and 309 of the Stafford Act, 42 U.S.C. §§ 5151-52
•	44 CFR Part 16: Enforcement of nondiscrimination on the basis of [disability] in programs or activities conducted by FEMA
Slide 3: FEMA’s Section 504 Disability Access Plan
•	Finalized on August 12, 2019
•	Outlines five focus areas to enhance inclusion of people with disabilities in FEMA program delivery and compliance with Section 504
•	FEMA must provide progress report to DHS by June 2020

Slide 4: What are FEMA’s public-facing programs and activities?
•	Disaster assistance
•	House inspections
•	Temporary housing units
•	National Flood Insurance Program
•	Responding to inquiries and/or sharing information with the public
Slide 5: What are FEMA’s public-facing programs and activities? (cont’d)
•	Job fairs or recruitments events
•	On-line and classroom training 
•	Events with members of the public as invitees
•	Contracting and procurement activities
Slide 6: Additional Requirements for FEMA’s Section 504 Disability Access Plan
•	Available to the public and posted as 504 Disability Access Plan at https://www.fema.gov/office-equal-rights
•	Welcome disability stakeholders’ questions and feedback about implementation

Slide 7: Five Focus Areas for Improvement
•	1.Public information, and platforms for distributing information, including public events and meetings;
•	2.Trainings and exercises; 
•	3.Noticing of the rights of people with disabilities;
•	4.Disaster assistance and recovery programs; and
•	5.Facilities.
Slide 8: Accessible Public Information and Platforms
•	Requirement: Effective communication access means information in a written, spoken, or alternative mode of communication is clearly understandable and actionable for the whole community.
•	Who needs effective communication access?
•	Deaf or hard of hearing
•	Blind or have low-vision
•	Cognitive or intellectual disabilities
•	Limited literacy
•	People who have limited English proficiency (LEP)
•	Others who may not self identify
Slide 9: Accessible Public Information and Platforms (cont.)
•	Access/Accommodations or Modifications, upon request
•	Alternative Formats – Braille, large print, electronic format
•	Conceptual plain language/accessible messaging

Slide 10: Strategies to Provide Accessible Public Information
•	Develop policies/programs to ensure effective communication access across the Agency taking into account ever-changing availability of services and technology 
•	Sign language interpreters/foreign language
•	Provide captioning, both in-person and remote; Fed Relay
•	Make original document (Word, Excel, PPT, etc.) 508 compliant/PDF/website 
•	Create 508 compliant videos (captioning and audio description) and also look at feasibility of including ASL interpreters, a 504 issue
•	Provide accessible messaging through pictograms and/or conceptual plain language 
•	Provide information in alternative formats
•	Include abbreviated Civil Rights Notice on all announcements for webinars, trainings, public meetings
Slide 11: Trainings and Exercises - Inclusive of People with Disabilities
•	FEMA trainings and exercises need to consistently include and integrate the needs of people with disabilities; and
•	FEMA needs to provide trainings and guidance on available contracts and mechanisms that provide effective communication access to people with disabilities.

Slide 12: Strategies to Provide Inclusive Training and Exercises
•	Update key FEMA training courses to add disability inclusion 
•	Provide Section 504 and disability access training to FEMA staff 
•	Ensure training videos include audio descriptions and captioning  
•	Explicitly include people with disabilities in FEMA videos and trainings, use person-centered language
•	Facilitate disability stakeholder involvement in National and other FEMA-led exercises
Slide 13: Publish Widely Civil Rights Notice
•	FEMA must provide Civil Rights Notice, include rights under 504 to request accommodations or modifications to access FEMA programs and activities
•	FEMA’s civil rights complaints process and the rights of the public under Section 504 must be well understood and noticed
•	FEMA needs to improve understanding of Section 504 requirements in its contracts for public-facing activities
Slide 14: Strategies to Publish Widely Civil Rights Notice
•	FEMA has an updated Civil Rights Notice, including: 
•	Who to contact if you feel your civil rights have been violated, and 
•	Who to contact for assistance (reasonable accommodation or language access need) in accessing FEMA programs and activities.

Slide 15: Role of Equal Rights Advisors at Disaster Operations
•	Post hard copy of Civil Rights Notice in Disaster Recovery Centers
•	Publish Notice widely through press releases, social media, and community partners
•	Emphasize FEMA’s affirmative responsibilities with respect to providing access to individuals with disabilities and information in appropriate languages to people with limited English proficiency
Slide 16: Role of Equal Rights Advisors at Disaster Operations (Cont.)
•	Include in FEMA announcements for webinars, trainings, and meetings Civil Rights Notice
•	Ensure field leadership’s explicit support for civil rights and setting the expectation for the operation
•	Show State, local, tribal, and territorial counterparts the importance of civil rights and providing access to disaster survivors
•	Engage community-based civil rights organizations to receive feedback on FEMA’s program delivery and proactively address concerns

Slide 17: Disaster Assistance and Recovery Programs 
•	FEMA’s delivery of assistance to survivors needs to consistently address the disaster-related needs of survivors with disabilities such as appropriate accommodations/modifications.
•	FEMA’s temporary housing programs needs to consistently provide people with disabilities appropriate accommodations/modifications.
•	FEMA must consistently integrate the needs and perspectives of people with disabilities in community-related recovery programs.
Slide 18: Strategies to Provide Inclusive Disaster Assistance and Recovery Programs
•	Offer disaster survivors with disabilities the opportunity to self- identify and accommodate their access needs from registration, including appeals, throughout the delivery of assistance
•	Use civil rights complaint data to educate leadership
Slide 19: Accessible Facilities
•	FEMA leased and managed facilities, including Disaster Recovery Centers at disaster operations, need to be fully accessible for people with disabilities
•	FEMA Occupant Emergency Plans need to consistently consider occupants and visitors who need accessible alerting and evacuation

Slide 20: Strategies to Provide Physical Access
•	Focus on parking, paths of travel, entrance doors, entrance vestibules, interior doors, corridors, toilet rooms, drinking fountains, visible and audible alarms, signage, wheelchair seating;
•	Involve Equal Rights Advisors in meeting/event planning and site inspections for physical accessibility at disaster operations; and
•	Confirm Occupant Emergency Plans consistently consider occupants and visitors with disabilities who need accessible alerting and assistance evacuating.
Slide 21: OER Responsibilities – Technical Assistance
•	Provides advice and guidance to FEMA senior leadership and program staff, to proactively address barriers to equal access and equal opportunity for people with disabilities
•	Provides technical assistance to FEMA program offices on providing reasonable accommodations or modifications to ensure equal access for people with disabilities
•	Coordinates with Equal Rights Advisors at disaster operations, regional personnel, and training facilities to support equal access
Slide 22: OER Responsibilities – Civil Rights Compliance 
•	Investigates civil rights complaints brought by members of the public, including disaster survivors, involving FEMA programs and activities
•	Receives civil rights complaints directly or through Helpline
•	Follows compliance procedures outlined in 44 CFR § 16.170 with respect to disability-related civil rights complaints

Slide 23: Contact Information
•	 Stephanie Fell, Civil Rights Policy Advisor/Section 504 Coordinator, FEMA
•	Stephanie.fell@fema.dhs.gov
•	202 368 8543