The AT Act requires AT Act Programs to “provide short-term loans of assistive technology devices to individuals, employers, public agencies, or others seeking to meet the needs of targeted individuals and entities, including others seeking to comply with the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.), the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.), and section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794)”. The purpose of a short-term device loan may be (1) to assist in decision-making; (2) to serve as a loaner while the consumer is waiting for device repair or funding; (3) to provide an accommodation on a short-term basis; or (4) for professional development. In the Annual Program Report (APR) Instruction Manual (word) a loan (counted as one) is defined as an occasion on which a device or devices were borrowed by an individual/entity who will use the device for one of the listed purposes.
Characteristics of Device Lending Programs
Device lending programs may be operated directly by the AT Act Program “central office”, partner agencies (e.g., that receive funds or devices to do one or more State-Level or State Leadership activities), or a combination. There may be one central location, regional sites, or a combination. Devices may be shipped by commercial carrier (e.g., FedEx), US Postal Service, or through other systems available in the state (e.g., inter-library loan). Some programs may require borrowers to pick up and/or return the device in-person, or use a combination of methods. A succinct description of the activity, including the process by which the majority of loaner devices are provided to the borrower, the process for obtaining devices for the inventory, the procedures used by borrowers to request devices, how the program tracks and ensures devices are returned and ready to be loaned out again, etc. is a component of the program’s State Plan for Assistive Technology (SPAT).
Section 4(e)(3)(B)(iii) of the AT Act requires that programs coordinate and collaborate their State-level and State Leadership activities among public and private entities. Accordingly, the SPAT and the Annual Performance Report (APR) will also include information regarding entities with whom the program has a formal written agreement to provide funding to the program for the purposes of device lending, as well as entities to whom the AT Act Program provides support.
Performance Measures and Required Data Collection Elements
In accordance with Section 4f of the AT Act, the Annual Program Report will include data on “the number, type, and length of time of loans of assistive technology devices provided to individuals with disabilities, employers, public agencies, or public accommodations through the device loan program and an analysis of individuals with disabilities who have benefited from the device loan program.”
Although there are many purposes for which devices may be borrowed, access performance measures are collected and reported ONLY with consumers who have borrowed for the purpose of making a decision (decided that an AT device would/would not meet their needs). No decisions are made, and therefore, no decisions are reported, when the device is borrowed as a loaner during device repair or while waiting for funding to provide an accommodation (no decision is involved), or for training, self-education or other professional development activity (no decision is involved).
Loans for all other purposes (providing a device during repair or while waiting for funding, providing an accommodation for a time-limited event, or for use in training or personnel development) are included in the acquisition performance measure (could only afford to borrow; AT only available through the program; could obtain but the system was too long or complex). For each borrower, data is reported on the category the borrower represents (e.g., education, employment, health, technology). Performance measures for both access and acquisition include the purposes for which the loan was made (for education, employment, or community living), as well as satisfaction. The Administrative Guidance document on leasing activities and related data reporting (word) helps to clarify how a leasing program can be structured.
Using Data for Program Improvement
Definitions (found in State Plan and Instructions 2018-20 and Instruction Manual for the State AT APR OMB Approved Dec 2021) should be reviewed with staff and subcontractors to ensure fidelity in your data collection. In particular, the categorization of devices should be reviewed in accordance with the device classification instructions in the APR. Review instructions regarding the purpose of the short-term device loan, and how to count device loans (e.g., when multiple devices are loaned at the same time to a single borrower).
Device Loan Numbers over Time
Is your total number of device loans changing over time? You can generate a report that compares this activity by year (e.g., FFY 2020, 2021, and 2022). You can also compare your program’s trend (e.g., increase or decrease) with the national trend data.
Ask: How can we explain the increase/decrease? e.g., due to an aging inventory, there is less consumer interest in device loans; due to leveraged funding we were able to substantially update our inventory; we started featuring devices for loan on social media. Is the change (increase or decrease) similar to that in the national trend data?
Decide: Do we want to increase the overall numbers of device loans? Do we need to do more outreach or use different strategies to let people know about the availability of device loans (especially any new products)? Are there implications for inventory purchases?
Purpose of Device Loan
Devices may be borrowed to assist in decision-making (requiring the collection of performance measures), to serve as a loaner (e.g., while the consumer waits for device repair or permanent funding), to provide an accommodation (e.g., providing a video magnifier at a conference registration table), or for training (e.g., for students to borrow in a graduate class on AAC, or for staff development).
Ask: Is the distribution of percentages by purpose of device loan similar to or different from the national snapshot? Has there been a substantial shift in purpose of device loan over time (e.g., comparing the program data from FFY 2020, 2021, and 2022 reveals a significant move from decision-making to accommodation); if so, how can that be explained (and is it a good thing)?
Decide: Do you need to change the focus of the purpose of device loans? How will you achieve this?
Device Loans and Device Type
How well do your device loans represent the full taxonomy of AT devices? You can generate a report that compares this activity by year, exploring the percentage of device loans by device category. You can also compare your program’s activity by device type with national data.
Ask: Why do we have so many device loans in some of the categories, and so few in the others? Does this reflect consumer demand in our state? Is our data different than the national data and why? How can we explain changes over time, and differences among the device categories? What are the implications for adding to our inventory?
Decide: Do we need to expand our inventory in one or more areas?
Device Loan Participants
Are you reaching the “targeted” populations described in the AT Act?
Ask: How can we explain the distribution of borrowers/device loan participants? For example, does the fact that the AT Act Program’s regional centers are primarily centers for independent living explain why most borrowers are people with disabilities and very few borrowers are from other targeted groups? Is this distribution desirable? How does the distribution of borrowers by role in our state compare with percentages by role nationally? Has there been a shift in distribution of device loan participants over the last three years and if so, how can we explain that?
Decide: Do we need to increase our outreach to one or more groups (which ones?), to increase their participation in device lending? Will a focus on specific targeted populations influence the selection of devices we should add to the lending inventory?
Device Loan Satisfaction
Are device loan participants satisfied with the device loan? You will want to be sure you are asking about satisfaction with your service, not the degree to which participants are satisfied with the borrowed device(s).
Ask: If satisfaction has increased dramatically (e.g., from 60% “highly satisfied” to 90% “highly satisfied”) what factors account for that trend? Or conversely, have we seen a decline in satisfaction? Are we asking the satisfaction questions the “right way”? Are satisfaction data for our program in alignment with national trends?
Decide: Do we need to get more information from participants about their satisfaction with our services? For example, if our satisfaction ratings are significantly better than the national percentages, what might explain that and are there things we are doing that are replicable by other programs? Can we discover why some consumers are only “somewhat satisfied” and learn what it would take for them to become “highly satisfied”?
Frequently Asked Questions
Must the AT Act Program conduct device lending?
No. Section 4(e)(6) of the AT Act allows a program to carry out any two or more of the four required state-level activities. This means the program can choose not to conduct up to two activities. If it chooses not to conduct device lending the program must claim either Flexibility or Comparability (word) in its state plan.
Does the program’s device loan program need to offer devices in all of the device categories?
A program may decide that certain device categories are not appropriate or feasible for device lending. For example, devices requiring extensive sanitization (e.g., commode chairs), installation (e.g., grab bars), or devices that are extremely heavy and difficult to transport (e.g., lifts) may be excluded as per the program’s policies and procedures. It is permissible to have collections of devices that target specific groups by type of AT, disability, functional need, or other parameters, as long as the total activity is comprehensive and provides statewide, cross-disability opportunities for consumers to borrow a range of technologies. For example, an AT Act Program may have leveraged funds from the VR agency to loan computers and adapted access technologies. Conversely, there may be another entity in the state that adequately supplies a particular category of devices, for example, if the state’s blindness agency loans braille note takers and video magnifiers.
Must the device loan program be available for consumers across the lifespan and across the state/territory?
In general, the programs and services of the AT Act Program are intended to serve all the state’s consumers, regardless of age or location within the state, in accordance with the AT Act’s requirement for a “comprehensive” statewide program. It is permissible to have collections of loan devices that target specific groups by age or geographic location as long as the “big picture” provides statewide, cross-age opportunities for consumers. For example, the AT Act Program may have leveraged funds to manage device loans for early intervention in a particular locality, or because another entity provides loans to children 0-21 the AT Act Program may choose to focus on lending devices to adults.
Can the same inventory of devices be used for lending and demonstration?
You may use the same pool of devices for lending and demonstration. In this case, you will need to develop a system to make sure your devices are available when you need them to fulfill a request for a loan or when you need them for a demonstration.
Is there a minimum or maximum length of time for device loans?
There is no definition of “short term” and programs may set their own parameters regarding length of loan. Short-term device loans have an end date by which they must be returned to the device loan program, and based on national data, this is typically between 30-45 days. Longer loan periods translate into a need for more items in the inventory. By contrast, devices that are loaned until the consumer no longer needs them are considered “open-ended loans” and these loans are counted as a reuse activity, NOT as device loan.
Can the program charge for device loans?
The AT Act Program may decide to levy a small charge to offset the costs of obtaining, maintaining, and/or shipping the devices. Any fees will need to be clearly described in the State Plan for Assistive Technology. Programs should note that fees may be a barrier for potential borrowers, and use these judiciously. If considering charging for shipping, it is recommended that the shipment to the consumer be at a small fee, but the return shipment should be free.
Must the decision made subsequent to a device loan (performance measure outcome) be related to the appropriateness of the specific brand/model of device(s) that was borrowed, or can the decision be more general (e.g., that some AT device would probably be useful)?
The options for the performance measures are (1) a decision was made that AT would help; (2) a decision was made that AT would not help; or (3) no decision was made. The performance outcome measure may be related to either a specific or general consideration of whether an assistive technology device might help. Even if the borrowed device was not helpful, the consumer still might be able to decide that AT would help.
Because our program uses a “drop ship” model to deliver and return items, it is very difficult for us to obtain performance measures from borrowers. How will this affect our ability to meet program goals?
The formula for device loan performance measures acknowledges the difficulty in obtaining information when there is little or no personal contact with borrowers. Accordingly, there is a 35% allowance for non-respondents that is used (only) for device loan performance measure calculations.
If one borrower requests a loan of three items at the same time in order to make a decision (e.g., to decide which model telephone provides sufficient amplification), is that ONE loan – or THREE loans?
If only one decision is being made, it is counted as one loan, even though there are three devices. The number of loans may not equal the number of devices.
If, on the same lending library application, a consumer requests a loan of three items that serve three different functions (e.g., a speech generating device, a tablet with an app for setting reminders, and a reacher), is that ONE loan – or THREE loans?
In this situation, the borrower is making three separate decisions. Each access decision is reported.
What can I do with equipment that is out of date or irreparable? Can I put it in reuse if it is still working, even if it is no longer sold or supported? Can I dispose of it if it is not functioning and is beyond repair?
You must follow US Department of Health and Human Services in this regard, as well as referring to the requirements of your lead agency or other entity that funded the particular device(s).
We were asked by another state’s AT Act Program to loan a piece of equipment to a consumer in their state, because that state’s program did not have it in its inventory and it was a critical (end-of-life) need for the consumer. Can we do this? If so, how do we count it? (who counts it?).
In general, the decision to loan an item from your inventory to a consumer in another state is yours. In making this decision, you may want to consider whether there is demand from your state (e.g., prioritize the needs of your state) and the involvement and responsibilities of the requesting state. Determine who will be responsible for costs (shipping; any costs related to damage or loss); reminders to the borrower and any efforts needed to retrieve the item; and which program will obtain and report performance measure data. This activity must NOT be double counted (e.g., counted by both programs).
Community of Practice in Demonstration and Device Lending
A schedule of upcoming Demo/Loan webinars can be found on our Webinars page.
View the Demo/Loan CoP page
Because both of these activities depend on access to and maintenance of an inventory of assistive technology devices, there is one combined Community of Practice (CoP) to address these two “access” activities. The CoP addresses topics ranging from procurement of discounts and donations; maintenance and repair; policies and procedures for centralized inventories; policies and procedures for programs requiring in-person collection/return; inventory management; and other topics of concern to the COP members. To join, email email@example.com.
HHS Policy on disposition of equipment