USDA is an equal opportunity provider, employer, and lender.

DATE: August 25, 2021

TO: RUS Telecommunications and Electric Borrowers and Awardees

FROM: Kenneth Kuchno, Deputy Assistant Administrator

Policy and Outreach System, Telecommunications Program

James Elliott, Director of Operations

Electric Program 

SUBJECT: Self-Evaluation and Transition Plans (Section 504 of the 

Rehabilitation Act of 1973) 

PURPOSE 

This memo serves as a reminder to Recipients, Grantees, and Borrowers in the 

Rural Utility Service (RUS) Telecommunications and Electric Programs of the 

requirements of Section 504 of the Rehabilitation Act of 1973 (Section 504) in 

regard to Self-evaluations (SE) and Transition plans (TP). On June 11, 1982, The 

USDA implemented Section 504 of the Rehabilitation Act of 1973 as promulgated 

by 7 CFR 15b. All RUS Recipients, Grantees, and Borrowers are required to 

conduct Self-Evaluations of their facilities, policies, procedures, and practices for 

compliance with Section 504 of the Rehabilitation Act of 1973. In the event that 

the self-evaluation identifies that structural changes are necessary, recipients are 

required to develop transition plans that set forth the steps necessary to remove the 

barriers.

Self-Evaluation (SE) Plans (7 CFR 15b.8(c))

RUS Recipients, Grantees, and Borrowers must complete a self-evaluation to be 

considered in compliance with 7 CFR 15b.

Minimum Requirements – the recipient must: 

• Evaluate, with the assistance of interested persons, including individuals with 

disabilities, or organizations representing persons with disabilities, its current 

policies and practices and the effects thereof that do not or may not meet 

regulation requirements. 

• Modify, after consultation with interested persons, including persons with 

disabilities or organizations representing persons with disabilities, any policies 

and practices that do not meet 7 CFR 15b requirements.

Rural Development

Civil Rights Office 

1400 Independence Ave SW 

Washington, DC 20250

Voice 202.692.0252

Fax 844-496-7792
• Take remedial steps to eliminate effects of any discrimination that resulted 

from the adherence to these policies and practices.

• The SE record must be available for public inspection and be provided to Rural 

Development upon request. In addition, the SE record must include:

o A list of persons consulted.

o The name of the person responsible for the SE.

o A description of areas examined and include any problems identified.

o Any modifications made or remedial steps taken.

• The recipient will maintain a record of the SE for at least three years if no 

transition plan is required. 

Transition Plans (TP) 7 CFR 15b.18(g) 

RUS Recipients, Grantees, and Borrowers shall operate each assisted program or 

activity so that when each part is viewed in its entirety it is readily accessible to 

and usable by persons with disabilities. 

A recipient/grantee must develop a TP for the removal of any structural barriers to 

accessibility with the assistance of persons or organizations who are 

knowledgeable about accessibility issues. 

Minimum Requirements – the recipient must: 

• Identify physical obstacles in the borrower’s facilities that limit the 

accessibility of its programs or activities to persons with disabilities. 

• Describe in detail the methods that will be used to make the facilities 

accessible, a transition plan setting forth the steps necessary to complete 

such changes. When structural changes are necessary, such changes must 

be made as expeditiously as possible. 

• Specify the schedule for taking the steps necessary to achieve full program 

accessibility, and if the time period of the TP is longer than a year, identify 

steps that will be taken during each year of the transition period. (It is 

strongly recommended that the TP include a written cost of estimates for 

all proposed actions). 

• Identity the person responsible for implementation of the TP. 

• A copy of the transition plan shall be made available for public inspection. 

The accessibility standards that must be met, The Architectural Barriers Act 

Accessibility Standards (ABAAS) for non-housing, ADA, in addition, many state 

and local governments have their own accessibility standards that must be met. RD 

does not have the authority to waive any accessibility standards, unless 

authorized by of the Secretary of Agriculture. 

For training or technical assistance please contact Civil Rights Compliance and 

Training Branch Chief Darren Kaihlanen, Darren.kaihlanen@usda.gov.