Melanie Brunson (email@example.com)
Director of Advocacy and Governmental Affairs, American Council of the Blind
On a recent business trip, I ducked into the hotel gift shop in between meetings to grab some energy food. Approaching the counter, I put down my purchase, handed the clerk what I thought was a twenty-dollar bill and said, "Here's twenty dollars." When the teller at my bank had handed me the bill shortly before I left for the airport, he had assured me it was a $20 bill, and I had folded it accordingly and placed it in my billfold in the compartment set aside for that denomination of bills. Therefore, I was surprised when the clerk said, "No, that's a $5. Here's your change." I protested that I had given her twenty dollars, but she said I had not. I explained that I had been told at the bank that it was $20, but she didn't care. Who was right? Since my purchase cost only $1.50, I cared how this question was answered. In this particular case, it happened that a colleague who could see was behind me in line and witnessed the transaction. She spoke up and said, "I saw her hand you a twenty-dollar bill, Ma'am." At that point, the clerk opened the drawer of the cash register, took out some additional bills, and slapped them on the counter in front of me. I picked up the bills, took my purchase, and left the store.
Though such incidents are not common, they do occur more often for people who are blind than many might like to admit. The incident described above was the most recent, but not the first, for this writer. It is always difficult to know how to handle these situations. In the U.S., coins of different denominations can be readily distinguished by people who are blind and visually impaired because the look and feel of each denomination is different. First of all, they vary in size and have different images. While pennies and dimes are close in size, pennies have smooth edges and dimes have milled, or ridged edges. On the other hand, banknotes are all the same size and texture, regardless of their denomination. While it is true that the images and numerals vary from one denomination to another, much of this information is indistinguishable by people who have limited vision, and cannot be identified at all by people who are blind. Therefore, for people who can't see their money, there is no way to verify the denomination of the bills, and in case of a dispute it may be difficult to determine who is right. People who are blind adopt various precautions to deal with this problem. For instance, it is common practice among people who are blind to separate their bills in some fashion, so they can identify them, either by where they are kept, or how they are folded. For example, one might keep one denomination of notes, such as $1 bills unfolded, then fold $5 bills in half, fold tens in fourths and fold $20 bills in half lengthwise. Anything larger might be folded into a triangle. Some blind people find it more useful to separate bills by placing them in different compartments within a billfold. When giving money to another person, such as a store cashier, it is common practice for people who are blind to state the denomination of the bill as they hand it to the other person, as was illustrated in the incident described at the beginning of this article. Others recommend avoiding the use of large bills altogether, so that only $1 bills and coins that are readily identified are received as returned change. In either case, one who cannot identify bills by sight has no means of verifying the denomination of bills as they change hands and one must exercise great care to prevent bills of different denominations from becoming mixed up. Further, if a bill is dropped, it can easily become unfolded, and one has no way to determine its previous location, so as to replace it in the proper compartment, or refold it in the appropriate manner.
Some people also use note identifiers. These are fairly small electronic devices which allow one to insert a bill into a slot and run it over a scanner. The unit then scans the bill and reads its denomination out loud through an earphone worn by the user. These units are popular with blind vendors and other business people who must be able to receive money and make change regularly. They work fairly well in many situations. However, the quality of their performance is influenced heavily by the quality of the bill inserted into the unit, as well as the ability of the user to hear the sound coming from the unit. The more worn bills become, the harder it is for the unit to identify them accurately. In many settings, there is so much background noise that it interferes with one's ability to hear the information that is coming through the earphone. For many people, the biggest problem with these units is their price. They cost between $300 and $400, which puts them out of reach for a large number of blind people. Indeed, none of these methods for identifying the denomination of banknotes is without flaws.
This dilemma leads one to question whether the United States government, which is charged by law with the production and circulation of paper currency, should not endeavor to address this problem and produce currency that is identifiable by people who are blind or visually impaired. It is my belief that there is both a legal obligation and a political justification for the U.S. Department of the Treasury to do so.
Section 504 of the Rehabilitation Act of 1973, as amended, states: "No otherwise qualified individual with a disability in the United States, shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance or under any program or activity conducted by any Executive agency, or by the U.S. Postal Service." This section further defines the erm "program or activity" as "all of the operations of (1)(A)a department, agency, special purpose district, or other instrumentality of a State or of a local government." See 29 U.S.C. 794.
The U.S. Department of the Treasury is an executive agency of the federal government. As such, it conducts "operations" for the government. Under the terms of this statute then, it is clear that it applies to the Department of the Treasury. Furthermore, Treasury Department regulations implementing the Rehabilitation Act specifically state that the Act applies to all activities conducted by the Department, with the sole exception of activities conducted outside the United States. See 31 CFR 17.102, which states: "This part applies to all programs or activities conducted by the agency, except for programs or activities conducted outside the United States that do not involve individuals with handicaps in the United States." (Emphasis added). If the production of currency is an activity of an executive agency, which is covered by Section 504 of the Rehabilitation Act, then the statute also requires that this activity be conducted in a manner which does not discriminate against people with disabilities.
The question then is whether the Treasury Department's current practice of making banknotes all one size, shape and texture so that they are indistinguishable from one another by people whose visual impairments prevent them from reading the print on the banknotes results in such people's being excluded from participation in, denied the benefits of, or being subjected to discrimination with regard to the use of these banknotes. Clearly, people who are blind can participate in the use of banknotes. However, as I have illustrated above, instances of discrimination involving the use of banknotes do occur against people who are blind, and they occur solely because one person involved in the transaction is blind and has no means of accessing accurate information about the denomination of a banknote. Even in transactions that do not involve fraudulent intent, the current design of U.S. banknotes places anyone who is unable to read them at a disadvantage. For such people, banknotes might as well be printed with invisible ink that is legible only to certain people, or through the use of special technology. Imagine what it would be like for the rest of our society if the Treasury Department decided that in order to prohibit counterfeiting, or protect some other national security interest, banknotes would be printed in invisible ink, which could be read only through a note identifier such as the one described above, or only by bank personnel. Would the people of this country accept such a scheme? I think not. Yet, that is precisely the circumstance people who are blind find themselves in, on a daily basis. It subjects them to inconveniences people who can see banknotes clearly do not face. It forces these people into situations which call attention to their impaired vision, and it puts them at risk of being defrauded, or otherwise taken advantage of, in financial transactions. Finally, it places limits on the types of jobs they can do, particularly for those with dual sensory limitation (such as people who are deaf and blind) who find it impossible to either use a note identifier, or to identify banknotes by other means. Therefore, it would seem that the "program" of currency production and circulation conducted by the United States Department of the Treasury does, in some instances, deny people who are blind the benefit of that program. Further, currency as it currently exists fosters discrimination against such people, solely because of their visual impairment.
Proponents of the status quo would argue that, although they are aware of this program's apparent shortcoming, alteration of paper currency to provide for easier identification by people with visual impairments would pose an undue burden on the government, as well as the business community. Therefore, they contend that it is not rational to attempt such alterations, and further, that Section 504 (supra) would not require the government to do so. They contend that the burdens of incorporating accessibility features into paper currency far outweigh the benefit such features would afford to society. So, just what would this burden involve, and who would bear it? In order to address these questions, we must examine what has been and what could be done to make paper currency readily identifiable by people with visual impairments.
In the 1980s, a bill passed the House of Representatives which would have instituted a system whereby paper currency would be shaped differently depending on its denomination. The proposed system involved clipping corners on bills to indicate which bill is which. For instance, a dollar bill may have all four corners intact, while a five-dollar bill might have four corners clipped, a ten-dollar bill three, a twenty-dollar bill two, etc. There were some concerns about protecting the integrity of the currency under this scheme, as well as its practicality, and the measure failed to win approval in the Senate. No further action was taken on the issue until 1995. In that year, the Treasury Department commissioned a study by the National Academy of Sciences to determine what measures could be taken to address this issue. The National Academy of Sciences convened a panel composed of leading experts in the fields of banknote design and currency production, anti-counterfeiting measures, materials composition and chemistry, as well as blindness and low vision research. The panel determined that within three years, it would be feasible for the Treasury Department to implement any of the following:
The panel also concluded that any of these measures could be implemented using currently available technologies and with minimal disruption of the financial industry. The entire text of this study can be viewed at http://www.nap.edu/catalog/4828.html?se_side.
To date, the only action the Dept. of the Treasury has taken in response to these recommendations is to place a large denomination numeral in the lower right-hand corner on the reverse side of most recently printed banknotes. The exception is the $1 bill, which was not altered when this feature was added to other bills. This is a small step, which is helpful to some people, and would seem to indicate that the department recognizes their obligation to address the issue of accessibility.
In the meantime, over 120 other countries around the world have taken much larger steps to insure that their paper currency is readily identifiable by people with visual impairments. These countries have incorporated into their banknotes some of the same accessibility features recommended by the National Academy of Sciences study. Canadian banknotes, for example, have large, high contrast numerals, and a dominant color which varies by denomination. The Canadian Journeys series of banknotes also goes even further by incorporating a tactile feature which allows people who are blind to identify specific denominations by touching a series of small raised dots located in the upper right-hand corner on the face of the notes. The dots are arranged differently for each denomination of notes. Both British notes and Euro notes vary in size by denomination and make use of high contrast numerals. All of these countries implemented these changes within a relatively short time, from the decision to do so, to the implementation, and the results have been accepted by their citizens without great difficulty.
One concern that is often raised in this country is that the public would not accept such a significant change in banknotes. However, the Treasury Department has made other significant changes to currency, both paper and coin, over the years in spite of public criticism. A case in point is the Susan B. Anthony dollar coin. Its introduction in the late 1970s was accompanied by tremendous public criticism. Some objected to the coin's imagery, but most people objected to the fact that it was very difficult to distinguish these $1 coins from quarters and people frequently interchanged them to their financial detriment. The "Suzies"--as they were affectionately called at the time--were the same size as quarters and could be distinguished from quarters only by the fact that they had a smooth edge, while the quarter's edge was milled. In addition, the two-dollar bill has gone in and out of circulation numerous times throughout American history, creating a whole new denomination for people to get used to each time it was introduced.
Another objection raised by the Treasury Department to the addition of accessibility features to the present banknotes is that such additions would constitute a significant alteration and require a massive public relations campaign to gain acceptance. However, the government is, as this article is being written, embarking on a public relations effort to let Americans know about the new anti-counterfeiting features it is already including in new banknotes to be issued in March 2003. In fact, such campaigns have accompanied other changes to currency throughout the history of governments including ours. It appears, then, that the idea of having to "sell" its currency is not a new task for the Department of the Treasury. Only the motivation for the change would be different, and we have been unable to obtain any evidence from the government which would indicate that this would impose any significant burden or additional cost to what the government already incurs for such campaigns.
Concerns have also been raised about the feasibility of implementing accessibility features such as those described above. However, features such as banknote color and numeral size could be addressed using the same intaglio printing process in use today, according to the report of the National Academy of Sciences cited above. The same report concludes that even the incorporation of tactile markings, or alteration in banknote size could be conducted using technology that is presently available to the government. No indication was given that such measures would add significantly to the cost of banknote production.
The question of whether the public would accept such features deserves comment at this point. Proponents of the status quo assert that accessibility features would significantly alter the appearance and functionality of banknotes to such a degree that the public might reject them as they did the Susan B. Anthony dollars. However, there is no hard evidence available to support this contention. Further, it assumes that the public will not find such changes in banknotes to be beneficial. Whether this is true or not may depend in large part on what percentage of the population has a visual impairment significant enough to make it difficult for them to identify current banknotes. As the population of the United States ages, the number of individuals with visual impairments will increase. As that population increases, the need for alterations in banknotes to make them readily identifiable by more people will grow as well.
Evidence from other countries indicates that it is feasible to implement a new system of currency. Further, even the U.S. government alters the composition and appearance of currency periodically in order to combat counterfeiting. Granted, none of the alterations undertaken by the government to date have been as significant as those proposed by the National Academy of Sciences. However, we see no particular reason why such alterations could not be incorporated into U.S. banknotes, just as they have been incorporated into those used by other countries.
With that in mind, the American Council of the Blind filed suit against the U.S. Department of the Treasury last year seeking to require them to make currency accessible to people who are blind and visually impaired. It is our hope that this action will provide the impetus for a serious effort to address this issue and take meaningful action to insure that blind and visually impaired Americans will have a level playing field when they enter the financial arena.
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