


DHHS POLICIES AND PROCEDURES
_______________________________________________________________________________________________________________
Section III:
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Communications
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Title:
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Communication Accessibility Provision Guidelines
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Current Effective Date:
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12/19/03
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Revision History:
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08/01/02
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Original Effective Date:
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08/01/02
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_______________________________________________________________________________________________________________
Purpose
Effective August 1, 2002, the Department of Health and Human Services (DHHS) established a policy for a uniform framework for requests by individuals who are deaf, hard of hearing, deaf-blind and blind for communications accommodations. The following guidelines are meant to serve as a framework for the development and reporting of the Communication Access Provision (CAP) plan and annual report to the DHHS Office of General Counsel. The plan may include, but not limited to, the provision of interpreters (sign language), the provision of TTYs, computer assisted note taking, assistive listening devices, Braille, written materials in large print, or cued language transliterating. (See Attachment I for definitions and for more details, Attachment II.)
Policy
All divisions/facilities/schools under the DHHS shall establish an accessibility plan to provide communication access for the consumers, clients, or staff who may be deaf, hard of hearing, deaf-blind or blind. The plan may include, but not be limited to, the provision of interpreters (sign language), computer-assisted note taking, assistive listening devices, Braille, written materials in large print, or cued language transliterating.
Implementation
- Each division/facility/school shall develop a written access plan to include:
- Name and contact information of the ADA Coordinator within the division/office/institution that serves as a central contact related to matters concern the DHHS Communication Accessibility Provision.
- A description of the methods used to assure appropriate accommodations for people who are deaf, hard of hearing or deaf-blind. For example, when contracting with individuals or agencies that provide accessibility services (e.g., sign language interpreting), the plan should describe the protocol for consumers, clients or staff to follow in obtaining these services.
- Description of staff development opportunities available for training in the various methods of manual and tactile communication. For assistance with training, please contact the DHHS Division of Services for the Deaf and the Hard of Hearing (919-773-2963) or Office of Education Services (919-715-7538). (See attachment III for skill verification of sign language interpreters or staff.)
- A description of how the policy is communicated to consumers and staff.
- A description of special outreach and media efforts (e.g., brochures in Braille or meeting notifications including contact person for special accommodations).
Annual CAP Report (sample)
Division Name:
Mailing Address:
Phone:
Name of Division Liaison:
Phone:
The following summarizes current data from (division name) for the reporting period of 00/00/00 to 00/00/00. The summary includes a compilation of data from the central division office and the following divisions/facilities/schools: (list)
I. Telecommunications:
Main Agency TTY number:
Number of TTYs within division:
Description of how TTY calls are answered if no TTY:
II. Interpreting:
Number of consumer requests for interpreting services:
Number of staff requests for interpreting services:
Total cost for consumer interpreting:
Total cost for staff interpreting:
Consumer/staff feedback (narrative):
III. Assistive Listening Devices:
Number of consumer requests for ALDs:
Number of staff requests for ALDs:
Total cost for consumer ALDs:
Total cost for staff ALDs:
Consumer/staff feedback (narrative):
IV. Brailling:
Number of consumer requests for Brailling:
Number of staff requests for Brailling:
Total cost for consumer Brailling:
Total cost for staff Brailling:
Consumer/staff feedback (narrative):
V. Other Communications Accommodations (e.g., CAN, CART, Other Auxiliary Aids and Services):
Number of consumer requests for other communications accommodations:
Number of staff requests for other communications accommodations:
Total cost for other communications accommodations for consumers in:
Total cost for other communications accommodations for staff:
Consumer/staff feedback (narrative):
VI. Additional Areas of Concern or Barriers that need to be Addressed:
Please send report to:
Office of General Counsel
NC Dept. of Health and Human Services
2001 Mail Service Center
Raleigh, NC 27699-2001
Reference:
DHHS POLICY AND PROCEDURE MANUAL. Communication Accessibility Provision (CAP). August 1, 2002.
ATTACHMENT I
This section defines the type of equipment or services that may be used to meet the need for communication access.
TTY – a type of text communication equipment that looks similar to a typewriter.
Computer Assisted Note taking - a visual display or summary of a speaker’s words is provided. It utilizes a note taker with specialized training that types on a standard computer keyboard but with special software that speeds up the process.
Interpreter - a sign language interpreter is a trained professional bound by a code of ethics, which includes strict confidentiality. The interpreter is there to facilitate communication only, and can neither add nor delete any information at any time.
ALDs (assistive listening devices) - personal amplification systems that can be used in face-to-face conversations, both 1-on-1 as well as small groups. They increase the loudness of specific sounds and bring the sounds directly into the ear.
Braille - a system of touch reading for people who are blind that employs embossed dots evenly arranged in quadrangular letter spaces or cells.
Large Print – converting print materials to large print, preferably 18-font size.
Cued Language - a visual communication system of eight hand shapes (cues) in four locations around the chin, that represent the different sounds of speech. These cues are used while talking to make the spoken language clear through vision. This system allows a client to distinguish sounds that look the same on the lips.
ATTACHMENT II
This section gives an in-depth explanation about the type of communication access and accommodations that are generally requested by individuals who are deaf, hard of hearing, deaf-blind and blind.
- Customer Service Guidelines Policy for the Text Telephone (TTY)
- What is a TTY?
- A TTY or TDD is a type of text communication equipment that looks similar to a typewriter.
- TTY = Teletypewriter (this is the preferred term)
- TDD = Telecommunications Device for the Deaf
- Using a TTY is a lot like using a walky-talky, a CB-radio, or typing in a Chat Room. The conversation is consecutive; only one party may talk at a time.
- TTY conversations can only take place if both parties have a TTY connected to each other via a phone line.
- If only one party has a TTY, you will need to use the State Relay Service.
- In addition to a screen, many TTYs also have a paper printer, which allows for a printed transcript of the complete two-way conversation to be made.
- TTY Etiquette
- Allow time for extra rings
- Always start by identifying yourself by name since your voice cannot be recognized.
- Complete sentences are often not needed; do use abbreviations, such as:
- GA = Go ahead
- Q = Question
- SK = Stop keying
- U, UR = You, Your
- PLS = Please
- PPL = People
- HD = Hold
- TMW = Tomorrow
- To show emotions and affect through paralanguage, type the following:
- Smile
- Grin
- Umm
- Sigh
- Arrgghh
- Grrrr
- Ohhh
- HaHaHa
- Grrrreeeaaattt
- XOXOXO
- W-o-w!!!
- Hugs
- When receiving a TTY call, you may hear either:
- Nothing (silence). VERY IMPORTANT: DON'T HANG UP IF YOU HEAR SILENCE!!!
- 2. loud electronic beeps (somewhat similar to the sound of a fax)
- An automatic message that says something like "Deaf caller, use TTY."
- Never interrupt a TTY conversation. Unless it is a true emergency, you should wait for the "GA" signal before you begin to type.
- "GA" stands for "Go Ahead." It is like the "Roger" or "Over" used with walky-talkies.
- Both TTYs and FAX machines make electronic beeps, but their sounds and patterns are recognizably different. Once you get used to the sound of TTY beeps, you won't confuse a TTY with a FAX.
- Sometimes messages will come out somewhat garbled, or come out in all numbers instead of letters. This is generally due to static on the line. If this happens, ask the caller to repeat what they just typed and let them know you had trouble reading them.
- Don't leave the other person on hold for too long without letting them know what is going on. They may think they were disconnected, or you hung up.
- Don't hang up until both parties have signed off with "SK."
"SK" stands for "Stop Keying."
- Dedicated TTY line
- Does your company list a TTY number in the telephone book, in its corporate brochure, on company letterhead, in promotional materials, or in a paid advertisement?
- If “YES,” when you call the published TTY number
- Are you ever hung up on?
- Does a receptionist who knows how to use a TTY correctly answer your call?
- Do you always get a TTY answering machine rather than a live person?
- If you leave a TTY message, is your call returned in a timely manner?
- Purchase of TTY
- For information on where to purchase special equipment, contact the DHHS Division of Services for the Deaf and Hard of Hearing at (919) 773-2963.
- Customer Service Guidelines for Oral and Written Communications
- Communication Questions
- Why do some deaf people choose to not use their voices?
- Why do some people who are “hard of hearing” prefer to call themselves “Deaf”
- Why do some deaf people use hearing aids?
- Lip Reading Facts
- Do not assume all deaf people can lip-read or speech-read.
- At best, only 30% of English speech is unambiguously identifiable on the lips. Many different sounds look the same on the lips.
- Lip-reading is a skill that some people have a more natural affinity for than others do. This ability is not at all correlated with intelligence.
- Some factors that may influence a given deaf individual's ability to lip-read effectively are:
- when they became deaf (pre- or post-lingually),
- their degree of hearing loss,
- whether they have any residual hearing, or
- their educational training (oral or manual).
- Some hearing people are easier to lip-read than others are.
- Some factors influencing ease of lip-reading include:
- speaker's facial expression and body language
- size and clarity of mouth movements foreign accents
- facial hair (beards and mustaches) that may obscure the lips
- environmental factors -- noise, lighting, background motion
- previous familiarity with the speaker
- Things you can do to make it easier to read your lips
- Face the deaf person and maintain eye contact.
- Don't have anything in your mouth (food, gum, cigarette, etc.).
- Keep your hands away from your face.
- Speak naturally and normally; don't speak extra slowly or exaggerate your mouth movements.
- Use ample facial expression and natural body language.
- If the message has not gotten across, try rephrasing using a short and simple sentence structure.
- English Skills
- English has long been the bane of deaf children. This is an area where many deaf children grow up feeling inadequate. First, consider trying to learn how to speak and lip-read a language you can't hear. For many this is an experience fraught with failure and frustration year after year. Second, consider trying to learn how to read and write grammatically correct English, when you can't hear what "sounds" right. In the normal course of development, hearing children learn to speak English fluently years before they learn how to read or write it. Later, when learning to read and write in school, hearing children rely heavily on knowing what sounds right - a channel not available to deaf children.
- To make the situation worse, enormous battles still rage today on what is the best way to teach English to deaf children. There is still a bitter controversy regarding oral vs. signing approaches. Another approach used in some deaf education programs is Manual English (also known as Manually Coded English or Signed Exact English), and it, too, is highly controversial. Overall, it is fair to say that the whole subject of English - both spoken and written - is a very emotionally charged topic for many deaf people that go back to their earliest years of childhood. How might these negative feelings about English manifest in the workplace? How might these feelings affect career advancement possibilities?
- One-on-One Communication Strategies
- Get the deaf individual's attention before speaking.
- Clue the deaf person into the discussion topic right away.
- Speak clearly and be sure your mouth is empty of food, gum, etc.
- Look directly at the deaf person; do not turn away.
- Do not place anything over your mouth when speaking.
- Maintain eye contact with the deaf individual.
- Avoid standing in front of a light source, such as a window or bright light, when speaking.
- Communicate in quiet places.
- Use open-ended questions rather than "yes" or "no" questions.
- First repeat, and then try to rephrase the statement or thought.
- Use pantomime, body language and facial expression to assist communication. Be creative!
- It's okay to point.
- Out of courtesy, inform the deaf person of any auditory information that might occur while you are speaking (e.g., phone ringing, knocks at the door, loud environmental noises, etc.).
- Take enough time to communicate.
- Customer Service Guidelines for Providing Interpreting Services
- What is a qualified interpreter?
- A sign language interpreter is a trained professional bound by a code of ethics, which includes strict confidentiality. The interpreter is there to facilitate communication only, and can neither add nor delete any information at any time.
- Do not ask the interpreter for his/her opinion or to perform any tasks other than interpreting.
- Before requesting a professional interpreter, ask the deaf employee if his or her has any interpreter preferences. Whenever possible, try to secure a preferred interpreter first.
- Freelance interpreters generally work as independent contractors - each with their own fee schedule and billing practices.
- Whenever possible, plan ahead and request interpreters at least one week ahead of time. In most locations there is a shortage of qualified interpreters, so the more lead time the better.
- Don't make comments to the interpreter that you don't mean to be interpreted to the deaf person.
- When using an interpreter, look directly at the deaf person (not the interpreter). Speak in a normal tone and speed. Speak in the first and second persons only (not third person).
- Example:
Correct: "Did you have any trouble finding us today?"
Incorrect: "Please ask him if he had any trouble finding us today."
- Types of interpreting (sign language, oral, tactile, etc)
- Sign language interpreting – ASL, signed English, or pidgin, the interpreter “visually” relays the spoken word to the student in whatever sign system is agreed upon.
- Oral interpreting – the interpreter ‘mouths’ the words spoken for the deaf or hard of hearing student. Sign language may sometimes be used as a filler.
- Tactile interpreting – is used by deaf-blind students who need to ‘feel’ the formation of signs that the interpreter is making. The student places their hands on the interpreter’s hands while interpreting. Some students can also use on-the-palm printing.
- Low-vision interpreting – is used by deaf / low-vision students who cannot see the interpreter from a distance. The interpreter and student face each other at a closer distance to enable the student to see the interpretation.
- Cued Speech transliterating
- Cued speech is a visual communication system of eight (8) hand shapes (cues) in four (4) locations around the chin, that represent the different sounds of speech. These cues are used while talking to make the spoken language clear through vision. This system allows a client to distinguish sounds that look the same on the lips.
- The primary goal of cued speech is to develop speech and language skills necessary for integration into the hearing community. A client learns to speak through the use of amplification, speech reading and use of cues, which represent different sounds.
- Coordinating Interpreting Services
- Staff is responsible for identifying the individual’s mode of communication/language at the earliest possible opportunity before or after the initial contact with your company/agency.
- Staff should utilize an interpreter with the highest type certification with priority given to interpreters with National certification or state classification “A” when possible with consideration of consumer’s choice.
- Normal reimbursement rates will apply during weekdays between the hours of 8:00 am to 5:00 p.m.
- During all other times and days, and during State recognized holidays, reimbursement will be at the rate of one and one-half times the normal rate.
- Interpreters will be paid for a minimum of two hours per assignment.
- Mileage and approved per diem expenses may be authorized at the allowable rates for state employees.
- When an interpreter contracts for an assignment, commits the time, and appears, the interpreter generally charges for the contracted time, whether or not the other parties show up. The interpreter may negotiate with the hiring party on how long the interpreter will wait before declaring a “no-show” and leaving.
- If an interpreter arrives for an assignment and it has been cancelled or the consumer does not show, the agency will be billed for full interpreter time and mileage. The agency would ask the interpreter to notify the appropriate agency contact person immediately to inform them that client did not appear for appointment.
- If an interpreter arrives late for a scheduled assignment due to an emergency, the Agency will only be billed for the time the interpreter actually worked. If the interpreter knows in advance that he/she will be late for an assignment, the interpreter should notify the appropriate agency staff immediately.
- Cancellation deadlines may vary from 24 hours to two (2) weeks, depending on the circumstances of the assignment. If an interpreter contracts for an anticipated number of hours, but the actual situation requires less time, the interpreter generally charges for all the hours reserved by the client.
- Interpreting assignments that last more than two (2) or three (3) hours generally require at least two (2) interpreters. The situation may be evaluated be a professional interpreter who can recommend the appropriate number of interpreters. The interpreter may seek information regarding the dynamics of the setting, the size of the audience and other factors that influence the need for more than one (1) interpreter.
- See attachment regarding skill verification of interpreters.
- Directory
- The DHHS Division of Services for the Deaf and Hard of Hearing distributes a Statewide Interpreter Directory and information packet each year.
- Customer Service Guidelines for Providing Assistive Listening Devices
- What is an assistive listening device?
- ALDs (assistive listening devices) are personal amplification systems that can be used in face-to-face conversations, both 1-on-1 as well as small groups. They increase the loudness of specific sounds and bring the sounds directly into the ear. These devices are often used in a variety of settings and offer mobility and flexibility when used with portable body-worn transmitters. Each ALD has at least three components: a microphone, a transmission technology and a device for receiving the signal and bringing the sound to the ear.
- What kinds of ALDs are available?
- ALDs can utilize FM, infrared or inductive loop technologies. All three (3) technologies are considered good. Each one has advantages and disadvantages and may be vulnerable to interference.
Each one:
- is cordless
- works well, generally speaking
- works with or without hearing aids
- can experience interference
- covers a wide area or personal versions
- ALDs vary in price, so comparison-shopping is wise. For effective use, staff who dispense them need to be trained on their use including the need to recharge and check batteries. ADA guidelines specify the number or percentage of receivers needed for an Assistive Listening System (ALS). Consumers can’t be charged to borrow devices from public facilities.
- Infrared systems (IR) work by transmitting sound via light waves to receivers worn by users. IR is commonly used in courtrooms, movies, and live performance theaters, conventions and with TVs. It allows privacy. It is susceptible to interference from bright sunlight. IR can effectively reflect off some surfaces.
- FM systems work by transmitting radio waves to receivers. They are commonly used in classrooms and where movement of speaker is required. They are not affected by light, can cover 200+ feet, are portable. They can be set to multiple frequencies to allow several uses in same place. FM systems are susceptible to radio interference.
- Sound field systems are essentially speaker boxes to bring sound closer to listeners. They are often used in classrooms. They are helpful to people with mild to moderate loss. They offer a secondary benefit to those who are not HOH. Sound field can be used with FM receivers that connect to the ear.
- Inductive or audio loop systems transmit through an electromagnetic field. No receivers are necessary for hearing aid wearers with a telecoil. Loop listeners or receivers can be provided for others. Loops are often permanently installed. Reception can vary and they are susceptible to interference.
- Corded ALDs such as the Pocketalker, Soundirector and Sound Wizard are relatively inexpensive compared with a hearing aid. Sometimes they are a helpful investment by those considering amplification for the first time. They are small and convenient. They are often used by those with no hearing aids.
- A variety of coupling devices is available to bring the sound into the ear. These include headsets, ear buds, neckloops and silhouettes. Some listening attachments are more appropriate or effective than others.
- Microphones can make a big difference in quality of sound. They are often the most expensive part of a system. Directional mics might be good for focusing on picking up the speech from a talker. An omni directional mic picks up sound from various angles and might be helpful during a conference. Consideration needs to be given to number and placement. Microphones ideally should not be stretched for more than three (3) people to a mic. Programmers need to realize when a pro audio sound contractor needs to perform an assessment. Sometimes consumers cannot set up an effective ALS using parts obtained from catalogues for residential use.
- If a consumer experiences problems with an ALD, troubleshooting is indicated. Many things can go wrong including a dead battery, the system not turned on; a broken receiver, consumer’s T-switch is not on, interference or a break in cords.
- CART, which stands for computer assisted real-time transcription, is a visual display of a speaker’s words. It utilizes court reporters that type on stenographic keyboards. CART provides a verbatim readout on monitor or screen. It can be used with either individuals or groups. It is ideal for lectures, classroom, courtroom or meeting. An edited printout or disk can be made available. A remote version of CART service is also available. This type of service provides CART utilizing the service of a person off site.
- C Print is a version of CAN - computer assisted note taking. A visual display or summary of a speaker’s words is provided. It utilizes a note taker with specialized training whom types on a standard computer keyboard but with special software that speeds up the process. A fast, accurate typist who can summarize performs it. Writing is displayed on a projection screen or laptop computer monitor. It is not as fast or accurate as CART. An edited printout or disk of notes can be made available. It is less expensive than CART.
- DSDHH – Regional Resource Center or Assistive Technology
For information on where to purchase Assistive Technology contact the DHHS Division of Services for the Deaf and Hard of Hearing at 919-773-2963.
- Customer Service Guidelines for Providing accessible print information
- How to Make Large Print Documents
- Follow the suggestions below to convert print materials to large print. Bear in mind that conversion will probably triple the length of a document.
- Font is 18 point Arial with single spacing
- Text is left-justified and in upper and lower case
- Use of italics, bold, and underlining is kept to a minimum
- Hyphenation at the ends of lines is kept to a minimum
- Paper is non-glossy and heavy to prevent show-through
- Tables are carefully constructed to allow tracking from one (1) column to the next.
- Use of parentheses ( ) is minimized
- Text is not crowded onto the page, and the number of pages is kept to a minimum
- Braille
- Some individuals who are blind read Braille. Braille is a system of touch reading for the blind that employs embossed dots evenly arranged in quadrangular letter spaces or cells. In each cell, it is possible to place six (6) dots, three (3) highs and two (2) wide. By selecting one or several dots in characteristic position or combination, 63 different characters can be formed. To aid in describing these characters by their dot or dots, the six (6) dots of the cell are numbered 1,2,3, downward on the left, and 4, 5, 6, downward on the right.
- Whenever printed handouts are shared in a meeting, accessible copies should be available at the same time.
- Print Materials: Audiocassette
Some people who have visual impairments cannot or prefer not to read Braille. People with learning disabilities may find audiocassettes easier to use than standard print materials. Even people without visual impairments use audiocassettes to "read" while they drive, do chores, or do other activities. Be sure to note in your print materials that the same materials are also available on audiocassettes.
- How can materials be produced in accessible formats for your Agency?
The Division of Services for the Blind maintains a Communications Unit that is able to produce information in large print, Braille and/or on audiocassette. For more information on how to have printed materials in accessible formats, call 919-733-9700 and ask for the Communications Unit.
- Customer Service Policy for Conducting a Meeting with Individuals who are Hearing, Hard of hearing, Deaf, and Deaf-Blind
- Ask the individuals with hearing and/or vision loss what kinds of accommodations are needed.
- Arrange for the most qualified interpreter(s) possible.
- Preferential seating is recommended to allow individuals with hearing and/or vision loss to utilize residual hearing and/or vision.
- If possible, use video presentations that are Closed Captioned (CC).
- Seat interpreters in positions that best allow for access to both visual and auditory stimuli without lighting being behind the interpreters or cart screen.
- Instruct participants to first, wait to be acknowledged the meeting chairperson before speaking and to state their name before making a comment.
- Remember the meeting will progress at a slower pace. Be patient.
- Because of lag time, please wait for the interpreter to finish signing or speaking.
- Presenters should use audio description to communicate any overheads, pictures, charts, etc. that are used in a meeting.
- Side conversations and noises as well as extended movement are very distracting to interpreters and people with hearing/vision loss. These distractions can render assistive listening devices useless. Keep distractions at a minimum.
- Make sure all handouts are in accessible formats.
- When in doubt about accommodations, just ask!
ATTACHMENT III
Skill Verification
Divisions, facilities or schools under the DHHS may use one (1) or more of the bulleted listing to verify the skill level of sign language interpreters, the sign language competency of staff or the appropriateness of programs or services. The need for skill verification may pertain to a division/office/institution directive or house bill. For example, House Bill 1313, a bill that was ratified and chartered by the General Assembly of North Carolina, Session 2001, Session Law 2002-182, is an act to establish the interpreter and transliterator licensure for persons who are deaf or hard of hearing and to make conforming changes to Chapter 8B and Chapter 143B.
- The skill level or range obtained by an individual through a Sign Communication Proficiency Interview (SCPI). This is sign language communication skills assessment tool. Individuals may obtain the following levels or ranges from Survival to Superior. For more information about this tool, contact: Drs. Frank Caccamise and Bill Newell, NTID/RIT, 96 & 52 Lomb Memorial Dr, Rochester, NY 14623-5604, feener@rit.edu and wjnncd@rit.edu, 716-475-620 and 6275, v/tty.
- The individual may be a Native ASL user who attended or graduated from a School for the Deaf or who may have deaf parents.
- For an interpreter, he/she may have a RID Certification. This is obtained through an application and testing process administered by the Registry of Interpreters for the Deaf. For more information, contact this organization at 333 Commerce St, Alexandria, VA, 22314, 703-838-0030 voice, 703-838-0459 tty.
- National certification may be obtained by an interpreter through the National Association of the Deaf, for more information contact the NAD interpreter Assessment and Certification Program, Executive Director, 301-587-1788 or NADInterp@NAD.org.
- To verify the certification of Cued Language Transliterators, contact TECUnit, Inc., at 301-434-1137.
- An individual may have attended or graduated from a program in Deaf Education, Sign Language Studies or Interpreter Training. Possible contacts regarding state and local programs:
Blue Ridge Community College – www.blue-ridge.cc.nc.us/
Central Piedmont Community College – www.cpcc.edu
Greensboro – www.uncg.edu
Gardner Webb University – www.gardner-webb.edu
Lenoir Rhyne College – www.lrc.edu
Western Piedmont Community College – www.cvcc.edu
Barton College – www.bartonl.edu
East Carolina University – www.ecu.edu
Wilson Technical Community College – www.wilsontech.cc.nc.us
Training or Consultation Contacts
The designated coordinator for a communication accessibility plan from each division/facility/school may contact the following for training or consultation.
- DHHS Division of Services for the Deaf and the Hard of Hearing, 919-773-2983, Sherry Bridges, Staff Interpreter/Coordinator.
- DHHS Office of Education Services, 919-715-7538, June Britt, Ombudsman


