Comment from Elsaesser, Linda-Jeanne , Elsaesser Consulting Inc.

Thank you for the opportunity to comment and present application of the ICF in a process standard for assistive technology. The Assistive Technology Service Method (ATSM) is an evidence-based assistive technology process standard based on international standards, models, and guidelines with identification of individual and public outcomes. The ATSM uses the common language of the ICF to establish a person-centered, cross-disability, interdisciplinary, trans-environmental transaction space to facilitate communication for assistive technology (AT) practice, education, research, and policy activities. The ATSM uses the common language and framework of the ICF to describe the context of the individual with disabilities (body functions/structures, activities and participation domains) including the impact of environmental factors as barriers or facilitators. ICF qualifiers are then used to define a baseline level of disability (impairments, activity limitations, and participation restrictions) and the impact of technology interventions on functioning. The ATSM demonstrates the usefulness of applying the ICF in actual disability evaluation procedures and establishes the infrastructure for capturing data on functioning including research in the business process for Federal disability programs. Recognizing the ICF currently “does not provide a uniform scheme for classifying individual characteristics that may affect the outcome of a potentially disabling condition”, the ATSM strengthens the ICF through application of current and emergent research (e.g.) biopsychosocial covariates in the Matching Person and Technology tools which have been harmonized with the ICF to meet this critical need.