The Department of Health and Human Resources (HHS): Before to the Olmstead decision, HHS had appropriated $2 million for "deinstitutionalization" and "community-based services" actions. HHS's efforts were reinforced by Executive Order 13217, requiring HHS and DOJ to "fully enforce Title II of the ADA" and prohibiting discrimination in state and local programs. Since Title II incorporates and expands Section 504, this was the first Executive Order helping states comply with the two laws and requiring each named agencies to review its own programs to "remove barriers that impede opportunities for community placement." In response, HHS identified ways that programs contributed to institutionalization, and reported how the Department responded to them. It created the Office on Disability and Community Integration (ODCI) to "serve as the focal point within the Department for disability issues, including the coordination of disability science, policy, programs and special initiatives within the Department and with other agencies." To assist the ODCI, HHS also created a Disability Advisory Committee consisting of individuals with disabilities, family members, advocacy organizations, providers, and state and local government officials. HHS also recommended the President formalize the Interagency Council on Community Living (ICCL), a council HHS convened, to accomplish Executive Order tasks and recommended that it be expanded to include other agencies, such as the EEOC and the IRS.

In the past 10 years, HHS's Office of Civil Rights (OCR) conducted more than 2,000 complaint investigations annually regarding civil rights obligations of grantees, including Section 504. Complaints filed with HHS decreased during the mid-1990s, with only 1,548 complaints filed in FY 1998, down from 2,222 in FY 1994. The number of complaints filed has risen steadily since FY 1999, with a projected 2,253 complaints anticipated during FY 2003.

Department of Education (ED): Until 1993, ninety percent of OCR resources were spent on responding to complaints and more than 50 percent of the complaints were disability related, involving Section 504 or the ADA. From its inception in 1980, ED was committed to treat civil rights with the same level of importance as other parts of the agency, headed by assistant secretaries; thus OCR has worked closely with the programs that focus on disability issues, such as the Office of Special Education and Rehabilitative Services (OSERS) and the Office of Elementary and Secondary Education. The second difference was, from the beginning, ED had its own legal staff enabling them to process complaints more efficiently. When OCR changed from a complaint-driven agency, it chose to expand its community and internal communication networks focusing its resources on the civil rights issues that most concerned the public and the staff through an intranet site that has links to several court decisions, laws, and regulations; relevant law review articles; and technical assistance. OCR is responsible ensuring schools, universities, state vocational rehabilitation agencies, nonprofit organizations, assistive technology providers, businesses, and others involved in its Olmstead efforts conduct their activities so that they are accessible. In its report to the President’s Executive Order, ED did not mention strategies to enforce the regulations and statutes it cites as supporting its Olmstead efforts.

In FY 2001, ED provided financial assistance to more than 25,000 recipients, including approximately 15,000 local education agencies, 10,000 post-secondary institutions, 57 state education agencies, and 82 state rehabilitation agencies and their subrecipients, amounting to $37 billion in Federal financial assistance. OCR received almost 38,000 complaints during the period 1994-2000, or an average of 5,244 complaints annually. As with HHS, complaints filed with ED dropped in the late 1990s, to 4,846 complaints filed in FY 1998 in comparison with 5,229 in FY 1997 and 6,628 in FY 1999. Although HHS disperses more funding and has more recipients, ED has filed and investigated many more complaints.

Department of Labor (DOL): When Congress expanded the Rehabilitation Act it also covered contractors working under Section 503. To enforce the civil rights laws applying to its grant program recipients, DOL created the Office for Civil Rights and renamed it the Civil Rights Center (CRC). All Section 504 investigations, technical assistance, compliance reviews, prefunding award reviews, and regulatory and policy development have been conducted in Washington, D.C. The budget for enforcement of the civil rights laws affecting recipients dropped to $1.9 million in 1988. The enforcement staff dropped from 66 in 1981 to 32 in 1988. By 1994, full-time enforcement staff had risen from 32 to only 34, and CRC's budget had increased to $2.5 million. By 2002, DOL's budget request for all of CRC's activities was $5.8 million, distributing most of its federal financial assistance through continuing state programs. These reductions have resulted in its reliance on Methods of Administration (MOA) documents. Required by both the JTPA in 1984 and the Workforce Investment Act (WIA) in 1998, the MOA is a document that describes the actions an individual state will take to ensure that its Workforce Investment Act (WIA) Title I-financially assisted programs, activities, and recipients are complying with the nondiscrimination and equal opportunity requirements of WIA. When CRC focused its attention in 1994 on the MOA requirement in the JTPA regulations it required every state to submit an MOA for review and guidance, incorporating best practices developed by disability organizations and individuals over the past 20 years. The CRC will collect information "to identify further areas in which federal training and technical assistance activities are needed to eliminate barriers and to prevent disability discrimination in the WIA program." CRC will also participate in "listening sessions" bringing people with disabilities, employers, parents and family members, providers of employment supports and services, and "other relevant stakeholders together to talk about changes needed to ensure meaningful and effective service delivery." However there is no indication that CRC plans to investigate Section 504 noncompliance that arises in these listening sessions. On the other hand, DOL's technical assistance, collaboration, and coordination plans, as described in its Olmstead Report, are both resource intensive and coordinated throughout the Department.

The Office of Disability Employment Policy (ODEP) has accomplished most of DOL's more recent work. Created in 1998, ODEP replaced the President’s Committee on the Employment of People with Disabilities. ODEP's mission is to increase opportunities for people with disabilities by expanding access to training, education, employment supports, assistive technology, integrated employment, entrepreneurial development, and small business opportunities. In contrast to CRC's $5.8 million budget for FY 2002, ODEP's budget is $38.1 million.

DOL's Olmstead Report reflects a clear understanding of the barriers to employment that exist and a commitment to spending the resources to address them. The DOL self-evaluation identifies plans to (a) help youth transition into the workforce, (b) work more closely with advocacy and community organizations, and (c) increase the employment of individuals with psychiatric disabilities, the supply of personal care assistants, and the use of technology in job finding and job retention. DOL follows the discussions of the barriers in each area and work plans.

Department of Justice (DOJ): In 1995 the Assistant Attorney General for Civil Rights created the Disability Rights Section (DRS) to enforce and to provide technical assistance throughout the Federal Government on all Section 504 and ADA matters. DOJ has also transferred the funding decisions to DRS. DRS has enforced Section 504 on a case-by-case approach, either from an individual complaint or as a "pattern and practice" case. Many cases involved state and local corrections agencies, requiring specific jails to become wheelchair accessible, police departments to hire sign language interpreters, and courthouses to provide materials to jurors on tape and in Braille. These cases have not resulted in broad-based systemic reform by ensuring compliance throughout the entity's programs. Neither DRS nor OCR has ever attempted to withhold federal funds from grantees that violated Section 504.

Until 1995, DOJ's Office of Coordination and Review worked on prototype Section 504 regulations; worked on Architectural Barriers Act matter; and provided technical assistance to the agencies. While the Office of Coordination and Review provided valuable assistance to the other federal agencies in each of these areas, it did not coordinate the enforcement of Section 504 throughout the Federal Government, as required under Section 507 of the Rehabilitation Act. Congress amended Section 507 in 1993 by renaming the Interagency Coordinating Council the Interagency Disability Coordination Council (IDCC). Congress also added the Departments of Transportation and Housing and Urban Development to the Council and expanded its and DOJ's responsibilities "to include monitoring and coordinating all efforts of the federal agencies concerning the rights of individuals with disabilities.

DRS developed and distributed close to 2 million ADA documents, fielded thousands of phone calls, worked with the IRS to notify 6 million businesses about the ADA in an IRS mailing, organized public hearings, and distributed millions in grant funds for education projects. In response to the Olmstead Executive Order, DOJ conducted a review of its own grant, litigation, and administrative programs to determine whether they promoted or impeded the ADA goals. DOJ also identified new litigation and education plans to respond to deinstitutionalization and integration barriers. DOJ's self-evaluation also identified barriers that limit the technical assistance and enforcement capacities of its Civil Rights of Institutionalized Persons Act office, its Housing and Civil Enforcement office, and its Corrections and Community Relations programs.