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Memorandum of Understanding on Artificial Intelligence

U.S. Access Board Memorandum of Understanding with American Association of People with Disabilities (AAPD) and Center for Democracy & Technology (CDT)

The Partners

The Access Board is an independent federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards. Created in 1973 to ensure access to federally funded facilities, the Access Board is a leading source of information on accessible design. The Access Board develops and maintains design criteria for the built environment, transit vehicles, public right-of-way, information and communication technology, and medical diagnostic equipment under the Americans with Disabilities Act of 1990 (ADA) and other laws. It also provides technical assistance and training on these requirements and on accessible design and continues to enforce accessibility standards that apply to federally funded facilities under the Architectural Barriers Act of 1968 (ABA).

The American Association of People with Disabilities (AAPD) is a national disability-led and cross-disability rights organization, promoting equal opportunity, economic power, independent living, and political participation for over 60 million Americans with disabilities.

The Center for Democracy & Technology (CDT) is a nonpartisan, nonprofit organization leading the advancement of civil rights and civil liberties in the digital age. CDT is at the forefront of discussions with policymakers and companies about responsible technology practices and conducts research and public advocacy to ensure artificial intelligence and other technology develops in a manner that is consistent with human rights and democratic values.

The Collaboration

The Access Board, AAPD, and CDT believe there is great value in establishing a collaborative relationship to engage with the disability and technology communities. Our goal is to communicate with the disability community to obtain input on equity and access to artificial intelligence (AI), and to connect with technology entities to integrate disability awareness and accessibility needs within mainstream technology conversations, policies, and practices.

The Access Board, AAPD, and CDT recognize that they are an integral part of a national effort to promote the safe, equitable, and accessible development and implementation of artificial intelligence.

Activities

Access Board, AAPD and CDT agree to work together to help ensure that people with disabilities benefit from AI while being protected from its risks. Areas of focus will include biometric discrimination, surveillance, maintenance of data privacy, and algorithmic governance and fairness. Potential activities may include:

  1. Establishing opportunities that promote solidarity, relationship-building, information-sharing across disability and technology communities.
  2. Identifying and developing possible solutions to potential or existing civil rights concerns, including:
    • accessibility barriers,
    • risks and benefits of AI, for example, in using biometric data as an input.
  3. Providing information, technical assistance, and access to resources that will enable disability and technology communities to promote and create safe, equitable, and accessible artificial intelligence.

Implementation

An implementation team comprising representatives of the Access Board, AAPD, and CDT will meet to develop a plan of action, determine working procedures, and identify the roles and responsibilities of the participants. In addition, they will meet at least three times per year, either in person or virtually, to track and share information on activities and results in achieving the goals and objectives of the goals and objectives of this memorandum.

The points of contact for the respective parties are as follows:

  • U.S. Access Board: Sachin Pavithran, Executive Director; Alison Levy, Director, Office of Technical and Information Services.
  • American Association of People with Disabilities: Maria Town, President & CEO; Henry Claypool, Technology Policy Consultant.
  • Center for Democracy & Technology: Alexandra Reeve Givens, President & CEO; Ariana H. Aboulafia, Policy Counsel, Disability Rights in Technology.

General Provisions

This memorandum provides the parties with an opportunity to participate in a voluntary, cooperative relationship that supports shared goals and furthers the national dialogue on how AI is designed, deployed, and regulated – with the goal of promoting equitable, fair, responsible, and accessible innovation that includes individuals with disabilities. In accordance with that understanding, the following provisions apply:

  • This memorandum will remain in effect for three years.
  • The Access Board does not endorse and does not promote any products or services of any party.
  • This memorandum may be modified in writing at any time with the concurrence of all signatories.
  • This memorandum is not intended to legally bind the parties, nor is it intended to confer any right upon any private person.

Nothing in this memorandum shall be interpreted as limiting, as superseding, or as affecting each party’s normal operations or decisions in carrying out its statutory or regulatory duties, or as limiting or restricting the parties from participating in similar activities or arrangements with other entities.

This memorandum does not itself authorize the expenditure or reimbursement of any funds. Nothing in this memorandum obligates the parties to make expenditures or enter into any contract or other obligations.

Signatures

In signing this memorandum, the Access Board, AAPD, and CDT demonstrate their commitment to ensuring the equity and access of artificial intelligence to include people with disabilities and to the goals and objectives described above.

Signed Wednesday, May 15, 2024 by:

  • Sachin Dev Pavithran, Executive Director, U.S. Access Board
  • Maria Town, President & CEO, American Association of People with Disabilities
  • Alexandra Reeve Givens, President & CEO, Center for Democracy & Technology