Designing Programs for Ensuring Access and Equity for Students with
Disabilitiesor
How to Avoid Jail-Time.Making Digital Resources Accessible.
Ray RoseRose & Smith Associates
This work by Raymond Rose is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.
Ray Rose
• Author: Access and Equity for All Learners in Blended and Online Education (November 2014) includes reviews of OCR Reports
• Author: Access and Equity in Online Classes and Virtual Schools (2007)
Who are you?
• K-12• Higher Education• Vendor/Publisher• Other
What do you do?
• Administrator• Program Manager• Course Designer• Course Instructor• Other
What questions would you like to get answered at this session?
Terms
• OCR – US Dept of Education, Office for Civil Rights
• DoJ – US Dept of Justice• Compliance – meeting legal requirements
Jail-time is not a penalty for creating, offering, or delivering online resources to students that are not accessible.
FWIW
Non-Compliance
Extreme: Loss of all Federal Funding for the institution
Typical Non-Compliance Situation: Negative Publicity Paperwork (lots and lots) Resolution Plan Ongoing monitoring by OCR
NJ School Compliance Plan 10/2014
The school district has committed to:• Work with an expert consultant, survey students, parents and
staff and assess current programs and courses to identify any potential barriers
• Consider expanding criteria to determine eligibility and selection for enrollment
• Expand student, parent, and community outreach about available courses and programs
• Improve academic counseling services at the middle school and high school levels
• Train district and school site administrators and personnel in elementary and middle school math enrichment programs and advanced courses.
http://www.washingtonpost.com/local/education/new-jersey-schools-promise-to-correct-racial-disparities/2014/10/28/2b14e800-5ede-11e4-8b9e-2ccdac31a031_story.html
Standards That Include Access…
• K-12– iNACOL– Quality Matters
• Higher Ed– Quality Matters– Online Learning Consortium (formerly
SLOAN-C)
Become Familiar with UDL*
• Universal Design for Learning– Multiple means of representation– Multiple means of Action and Expression– Multiple means of engagement
* referenced in iNACOL National Standards for Quality Online Courses
http://www.cast.org/udl/
UDL ≠ Legal Compliance
Your institution’s obligation:
Meet legal requirements for accessibility in every online course. (That includes blended offerings.)
OCR’s Operational Definition
“those with a disability are able to acquire the same information and engage in the same interactions —and within the same time frame — as those without disabilities.”
OCR Compliance Review 11-11-2128, 06121583, paraphrased from 11-13-5001, 10122118, 11-11-6002
Your text hereYour text here
OCR Finding
Section 504of the Rehabilitation Act of 1973
Section 504
Section 504 of the Vocational Rehabilitation Act of 1973 (Vocational Rehabilitation Act, 1973)
– mandates that qualified people with disabilities have access to programs and services that receive federal funds
Institutional 504 Basics
• Appoint 504 Coordinator• Establish 504 Grievance Procedure• Provide annual public notice of Coordinator
and Grievance Procedure
U. S. Department of Justice(DoJ)
• Enforces: ADA, 504, IDEA, Title IV, Title IX
• if qualified individuals with disabilities enroll in online courses, these courses must be made accessible to them
ADA
Title II, Americans with Disabilities Act of 1990
ADA
Americans with Disabilities Act (ADA) of 1990 (Americans with Disabilities Act, 1990)
– reinforced and extended Section 504– prohibiting institutions from excluding and
otherwise discriminating against students with disabilities in public programs and services,
– regardless of whether or not they are federally funded
http://www.ada.gov/2010_regs.htm
OCR Finding
Section 508 of the Rehabilitation Act 1973
• Section 508 of the Rehabilitation Act of 1973 (U.S. Department of Education, 1998), – requires that electronic and information technologies
that federal agencies procure, develop, maintain, and use
– be made accessible to people with disabilities, both employees and members of the public,
– unless it would pose an undue burden to do so.
• The Vocational Rehabilitation Act Amendments (1998)– mandated the U.S. Architectural and Transportation
Barriers Compliance Board (Access Board) to develop accessibility standards for electronic and information technology to which federal agencies must comply
* “The use of the Accessibility Standards by OCR does not imply that conformance to Section 508, WCAG, and/or other electronic and information technology standard is either required or sufficient to comply with either Section 504 or Title II. Rather, OCR’s limited application of the Accessibility Standards served only as an investigative line of inquiry, assessing the designated website against specific technical requirements, which may indicate potential compliance concerns under Section 504 and Title II.”
*OCR Compliance Review: Docket #15-11-5002 *Boilerplate from OCR Compliance Reports
Web Content Accessibility Guidelines (WCAG) 2.0
• Perceivable• Operable• Understandable• Robust
http://www.w3.org/TR/WCAG20/
Web Content Accessibility Guidelines (WCAG) 2.0
• Perceivable–Text alternatives–Time-based media alternatives–Content can be presented in different
ways–Easier for users to see and hear
content
Web Content Accessibility Guidelines (WCAG) 2.0
• Operable–Keyboard functionality–Time constraints removed–Sensitivity to seizure-inducing design–Easily navigate and find content
Web Content Accessibility Guidelines (WCAG) 2.0
• Understandable–Text content readable and
understandable–Web pages are predictable in
appearance and operation–Help users avoid and correct mistakes
Web Content Accessibility Guidelines (WCAG) 2.0
• Robust –Maximize current and future user
compatibility–Including assistive technologies
OCR Finding
POLICIES
Policy Recommendation
Adopt quality standards for all online learning activities
Policy Recommendation
Review ALL courses to insure they are legally accessible
Policy Recommendation
Create process, responsibility, and timeline for retrofitting or replacing non-compliant courses
Policy Recommendation
Create a Special Needs Online Learning Policy
Policy Requirement
Ensure institution has:– 504 Coordinator– 504 Grievance Policy, and – Annual 504 Notifications
Policy Requirement
There is no gateway exam required to participate in online learning
Policy Requirement
Institutional website meets legal accessibility requirements
COURSE DESIGN
Think Print disability
• Includes:– Visual Print-disability– Physical Print-disability– Cognitive and/or Perceptual Print-disability
Course Design
Pay attention to color (color blind)
Course Design
Graphics• Alt Tag EVERYTHING• NO Eye Candy
Course Design
Captioning for Video andTranscripts for AudioARE NOT A LUXURY
Course Design
Everything needs to be accessible -- inside and outsidethe LMS
Course Design
Make PDFs searchable(If a graphic, follow requirements for graphics)
Course Design
Course navigation without a mouse is possible
Course Design
Courses reviewed with a screen reader*
*Screen reader info in Resources
More..
• Think UDL -- use Alternate Presentations
• Live Video needs to be accessible
• Caption Lecture Capture
Do NOT trust any vendors’ word on accessibility.
– 6 different vendors’ materials cited by OCR in various compliance reports.
PROGRAM and
COURSE MONITORING
Monitoring
Collect disagreggregatedenrollment data for all online courses and programs
Monitoring
Analyze enrollment data for comparison with sending population
Resources
FREE Video Captioning Apps• NCAM.wgbh.org
–MAGpie–CC for FLASH
Resources
Adobe and Accessibility website (PDF info)• www.adobe.com/accessibility.html2014 Access and equity for all learners in blended and online education• http://inacol.org2007 Access and Equity… Publication• http://files.eric.ed.gov/fulltext/ED509623.pdf
Resources:
Color Blindness Simulator
http://www.seewald.at/en/2012/01/color_blindness_correction_and_simulator
See through the eyes of your red, green or blue colorblind student.
Android
Resources
FREE website accessibility testers• http://CynthiaSays.com• http://WAVE.webaim.org• https://amp.ssbbartgroup.com/expr
ess
Resource: Free Screen Reader
NVDA http://www.nvaccess.org/
NVDA (NonVisual Desktop Access) is a free “screen reader” which enables blind and vision impaired people to use computers. It reads the text on the screen in a computerised voice. You can control what is read to you by moving the cursor to the relevant area of text with a mouse or the arrows on your keyboard.
Contact Info
Raymond Rose– [email protected]– 512.791.3100
Slides available at SlideShare.netunder RaymondRose