Transcript Best Practices in Digital Accessibility

Kristi Harris
U.S. Department of Education
Office for Civil Rights
Korey Singleton
George Mason University
Bisi Ladeji Okubadejo
Ballard Spahr LLP
© All rights reserved
Agenda
 What is the issue? What is EIT “in-accessibility”?
 How does this fit in with Section 504 and the ADA?
 What does the government look for during an
accessibility review?
 How have schools addressed the issue?
 The GMU model
 What are some best practices?
 What are recommended first steps an institution
should take to address EIT accessibility?
What We Know...
 Increasing numbers of students with disabilities
entering IHE
 Greater implementation of online/e-learning
technologies in higher education classrooms (online
and F2F)
 Growth in distance education offerings by IHE
 Growing number of legal challenges/findings against
IHE by individuals with sensory impairments
(visual and/or hearing loss)
Common Issues
 Inaccessible LMS’ and supplemental applications
 Alternative texts (textbooks)
 Document accessibility (Word, PPT, PDFs)
 Captioning for videos
 Inaccessible library resources (databases, search, print

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

resources)
Additional classroom resources (e.g., iClicker, podiums)
Inaccessible university websites/web resources
ATMs
Access to auxiliary offices (financial aid, registrar)
- What is Assistive Technology?
- Demos and Examples
(Documents, Websites, and Web-based applications)
Assistive Technology
 Definition: Disability-specific devices that allow
people to use computers and other technology
 Alternatives, such as foot pedals, for people who
cannot use a computer mouse
 Screen readers and refreshable braille devices for
people who are blind or have other print disabilities
 Open or closed captioning for people who are deaf
Anatomy of an Accessible
Document
Document courtesy of Portland Community College: http://www.pcc.edu/resources/instructionalsupport/access/documents/OnlineAccessibilityHandbook-loRes.pdf 0
Jaws Screen Reader Demo
 E.g., Navigating a Word Document (a screen reader
user’s perspective)
Video courtesy of High Tech Center at Taft College:
https://www.youtube.com/watch?v=D8XFkGMF0sw
Before and After Demo - Websites
 E.g., Improving a website using Web Content
Accessibility Guidelines (WCAG) 2.0,
http://www.w3.org/WAI/demos/bad/
Understanding Web Accessibility
 E.g., Labeling Images/Graphics
 Graphics should have meaningful labels:


Ex: “Photo of Secretary of Education Arne Duncan reading
to children at Central Elementary School.”
Not: “Photo”
 The labels can be visible to everyone, or they can be
hidden in the programming of the web page.
Designer’s choice!
Understanding Web Accessibility
 E.g., Color Contrast
 Meaningful
information should be
conveyed through
more than just color.

For example, “stop” and
“go” functions should not
be signified solely
through the use of green
and red buttons. Instead,
red buttons should be
labeled “stop” and green
buttons should be labeled
“go.”
Understanding Web Accessibility
 E.g., Keyboard
Navigation
 Users should be able to
“tab” through the page
and get to all
information and
functions.
 Pages should not
require users to
manipulate a mouse for
navigation.
Web-based Tools – Library Databases
(Full-text HTML, ReadSpeaker)
Ability to translate text
Downloadable
mp3 file
Also available as
separate PDF
Built-in text-to-speech capability
Text Highlighting
Web-based Tools – Films on Demand
(Captions and Transcripts)
Interactive Transcript
Captions
Searchable Video Content
- Sect. 504 and ADA
Legal Requirements
 Applicable laws:
 Section 504 of the Rehabilitation Act
 The Americans with Disabilities Act
 Qualified individuals with disabilities must receive
equal access to all of a recipient’s programs, services,
and activities.
Legal Requirements
 What is “equal access”?
 OCR’s guidance on emerging technology sets the
standard.


“Receive all the educational benefits provided by the
technology in an equally effective and equally integrated
manner”
Must be able to:
 Acquire the same information,
 Engage in the same interactions, and
 Enjoy the same services.
Legal Requirements
 Separate offline access?
 “An agency with an inaccessible website may also meet its
legal obligations by providing an alternative accessible way
for citizens to use the programs or services, such as a
staffed telephone information line. These alternatives,
however, are unlikely to provide an equal degree of access
in terms of hours of operation and the range of options and
programs available. For example, job announcements and
application forms, if posted on accessible website, would be
available to people with disabilities 24 hours a day, 7 days a
week.”

U.S. Department of Justice’s “Accessibility of State and Local
Government Websites to People with Disabilities.” (Available at
www.ada.gov)
Legal Requirements
 Regulations
 Under Section 504 and Title II, recipients and public
entities must ensure that qualified persons with
disabilities have an equal opportunity to participate in
the entities’ programs, services, and activities.
Legal Requirements
 Fundamental Alteration Defense
 Covered entities do not have to do anything that
would fundamentally alter the nature of the program
or service they are providing.
 Ex: U.S. Geological Survey’s topographic maps cannot
be reduced to words to make them accessible to
people who use screen readers. The very essence of
their “mapness” would be destroyed in the process.
Legal Requirements
 Undue burden defense
 Covered entities do not have to do anything that
would impose an undue administrative or financial
burden.
 Ex: It might be an undue burden for a small college to
try to meet a blind student’s last-minute request to
provide audio-description for an online student film
festival.
 Note: The administrative requirements apply to
“undue burden” and “fundamental alteration” here as
throughout Section 504 and Title II.
Legal Requirements
 Websites v. distance learning
 Distance learning: the technology supporting “live” courses
should be designed to be adaptable (no need to actually
provide real-time captioning, if there’s no student who
needs captioning currently enrolled, but educators should
be ready to do so if a student with disability joins the class).
 Websites: all websites should be designed to be accessible to
individuals with disabilities.
 The intersection of websites and distance learning: if an
archived course is available online upon demand, then it
should be captioned before posting – or the educator
should be ready to provide another means of effective
communication.
- WCAG 2.0 and Sect. 508
Useful Guidelines
 Useful guidelines for web accessibility
 Web Content Accessibility Guidelines (WCAG 2.0)
from the World Wide Web Consortium (W3C)
 Section 508 of the Rehabilitation Act of 1973, as
amended in 1998
Useful Guidelines
 WCAG 2.0 Guidelines
 Web accessibility initiative of the World Wide Web
Consortium “W3C”

Public/private consortium, world-wide, of academics,
governments, technology industry, and user groups
 Web Content Accessibility Guidelines

Optional for all web developers, including governmental
entities
 www.w3.org/wai

Especially: “Evaluating Accessibility”
Useful Guidelines
 Section 508 Only Applies Directly to the Federal
Government
 Federal agencies must comply with the Section 508
standards
 Others may use the Section 508 standards as guidance, but
are not subject to Section 508 itself (except under some state
laws)
 Important: Section 508 does NOT “follow the money” like
Section 504.
 Section 508 Resources:


www.section508.gov
www.access-board.gov
- Compliance reviews
- Best Practices
Governmental Review
 University of Cincinnati compliance review
 Youngstown State University compliance review
 University of Phoenix
Best Practices
 Based on compilation of findings from settled EITA cases
 Here’s your roadmap!
 Establish/update Electronic and Information Technology (EIT)
Accessibility Policy
 Establish/update EIT Grievance/Remediation Process
 Establish/update Procedures for Procurement
 Establish EIT Accessibility Training
 Establish Accessibility Web Portal/Website
 Hire EIT Accessibility Staff
 Establish Process for Monitoring EIT Issues
 EIT Accessibility Audit
 Institution-specific resolutions (e.g., monetary compensation,
department-specific applications/websites, establish nondiscrimination policies)
- Policy & Procurement, IT Accessibility Working Group
Comparing Mason…
 National cases had Mason equivalents!
 MyLabs and other supplemental applications
 Captioning
 Inaccessible websites/web-based documents
 DE courses
 Communication breakdowns
 Purchasing/procurement issues
 University’s IT infrastructure was changing
 Shift away from ‘siloed’ delivery model
 Enterprise systems overhauled/updated
IT Accessibility Working Group (ITAG)
 Established in/met throughout Spring 2013 and Spring 2014
 Stakeholders from Library, UL, ITS, CTFE, DE, Legal, Academic
Depts., and CDE
 Issues and challenges centered on addressing needs of students with
sensory impairments
 At the time (Fall 2012), we had 81 total students with sensory
impairments…included 8 incoming blind students (both grad and
undergrad) and that total was almost 50/50 in terms of the number of
students with vision and/or hearing loss
 Information available on our website: http://ati.gmu.edu/policy/it-
accessibility-working-group/
Issues Identified by ITAG
 Accessibility vs. Accommodation (Medical Model)
 JIT (Adjuncts) vs. Development
 Time/Staffing/Costs
 Inconsistency within and across programs
 Compliance/Enforcement
 Costs
 E-Learning Technology
 Legal Issues
 Non-Inclusive Practices/Awareness
 Procurement
High Priority/High Impact Recommendations
 Improving Student Access in the Classroom
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Provost’s Letter
Established Baseline Design Considerations (captioning, accessible document
design)
Accessibility reviews for DE courses
Improved communications/collaboration
Training with Academic Units/Depts./Instructional Designers
Accessibility testing of e-learning and IT resources
 Improving Web Accessibility/Procurement
ASRB Changes/Updates
 Prioritization of websites for accessibility testing

 Structural Improvements
Video management platform
 Staffing for document accessibility support

- Communication/Collaboration
- Policy Updates
Improving Communication and
Collaboration
 Top-down Approach
Provost’s letter
 Meetings with Deans/Directors


Identified Accessibility Liaisons for each College/School
 Emphasis on Strategic Partnerships (Choke Points)
Joint meetings with faculty members that will have a student with a sensory
impairment in their courses (ATI/Disability Services)
 Collaboration with ID Team and Office of Distance Education
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Accessibility training provided for Academic Units c/o Instructional Designers (IDs)
Course Portfolio Accessibility Reviews [Pilot Tested – May 2015]
Collaboration with Library (AT Labs, e-Reserves, Captioning, Procurement)


Accessibility Coordinator position established
Streaming Media Policy
EIT Policy Updates
 Policy 1307 – Procurement and/or Development of Administrative
Systems/Applications
 Updated in 2012 to reference the Architecture Standards Committee
 Architectural Standards Review Board
 ASRB reviews all technology purchases
 Policy 1308 – Electronic and Information Technology Accessibility
 Updated April 2014
 Expanded definition for “electronic and information technology”
and whom it applies to
 Roles and Responsibilities
 Findings and Recommendations from IT Accessibility Working Group
Architecture Standards Review Board
 The ASRB is under the Architecture Standards Committee (ASC) and is responsible
only for approving the beginning of a given project.
 Initial review includes an accessibility review by ATI and any other reviews (e.g., IT
security, cloud computing, integration, etc.) necessary. At the ASRB’s discretion,
changes may be required before approving a project.
 Projects under the purview…include all requests for new development, installation
and/or integration of applications at GMU…includes activities from internal ITS,
Mason University offices, mobile apps developed by university faculty and staff, and
all software produced by 3rd party vendors and consultants including pilot
projects…committee will not review upgrades, bug fixes, and incremental
improvements to existing programs.
 ATI provides a risk analysis and recommendations for Mason purchaser.
Definitions Matter (Our EITA Policy)…
 Lifted the definitions from Penn St. Settlement…
Accessibility –
“…individuals with disabilities are able to independently acquire the same information, engage
in the same interactions, and enjoy the same services within the same timeframe as individuals
without disabilities…”
Electronic and Information Technology –
“…. electronic and information technology includes, but is not limited to, the internet and
intranet websites, content delivered in digital form, electronic books and electronic book reading
systems, search engines and databases, learning management systems, classroom technology
and multimedia, personal response systems(“clickers”), and office equipment such as classroom
podiums, copiers and fax machines…”
Purchasing Contract Language
 Worked with Purchasing, ITS, and Legal to include
accessibility language on all purchasing contracts,
including eVA purchasing agreements.
 Sample purchasing agreement language -
http://ati.gmu.edu/policy/procurement/
 Added protection for technology purchases that are not
reviewed for accessibility.
- Training Resource Updates
Baseline Design Considerations
for Accessible IT Resources
 Visual:
 Provide alternative text descriptions for all meaningful graphics (images, charts,
graphs, SmartArt, objects)
 Provide descriptions for videos where visual content is important to
understanding subject matter.
 Use styles in Office documents, headers to mark-up tables or frames (for websites)
 Choose applications that support keyboard navigation and are compatible with
screen readers
 Hearing:
 Provide captions for all videos
 For audio, provide transcripts
 Cognitive, Neurological:
 Use consistent navigation, tab order, appropriate language level
Guide to Creating Accessible
Electronic Materials
JIT training resource provides
faculty/staff with step-by-step
instructions on ensuring that
their electronic
documents/videos are
accessible to individuals with
disabilities.
http://ati.gmu.edu/wpcontent/uploads/Guide-toCreating-AccessibleElectronic-Materials-7-MBpdf.pdf
Sample #1 – GOALS Document
Sample #2 – ATI Created
Updated ATI Website
Website: http://ati.gmu.edu
 Usability-group tested
 Easier navigation
 2 important updates…
Video Training Library
Streamlined Services Request
Process
- Structural Improvements/Workflow Updates
Captioning Workflow - Kaltura Pilot
• ITU purchased and implemented Kaltura video
management platform during Spring/Sum 2014…full
implementation Fall 2014/Spring 2015
• Solved a number of captioning issues
• Easy process for addressing last-minute requests
• Standardized video management process
• RFP for captioning/transcription vendors with Kaltura
partnerships
• Streamlined workflows/timelines/costs
• Allowed for scalability
• Integrates with LMS
What the numbers show…
Completed Accessible Media Requests
1296
1034
337
147
FY12
FY13
FY14
FY15
Who’s Using the Service?
 Over 180 faculty/staff members have made requests
 Top 3 Schools/Colleges/Units making requests
 Volgenau School of Engineering
 College of Humanities and Social Sciences
 College of Science
 Reasons for Request
 Compliance for DE Course – 70.6%
 Compliance for F2F Course – <1%
 Web Compliance – 2.8%
 Disability Accommodation – 25.5%
Website and Applications Testing
 University Web Audit (FY14) to prepare for new WMCS
 Provided accessibility reviews, which were included in
University’s web audit
 Reviewed Priority 1 and Priority 2 websites (over 110 websites)



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P1: Academics, Admissions, Financial Aid, Student Health, Housing, Visitors, HR
P2: Individual College and School websites
Page scans 5 levels deep, up to 100 pages
Reports provided to Web Developer
 ATI Web Testing Process
 Automated testing using AMP
 Manual testing in-house using Jaws/NVDA
Website and Applications Testing
cont.…
 University recently selected new WCMS to updated web presence
and standardize branding
 Currently working with ITS and Marketing on incorporating
accessibility into design process
 Websites are currently in same situation that videos were in a few
years ago…
 A few different WCMS’ in place (CommonSpot, WordPress)
 Some developers use their own WSYIWIG (e.g., Dreamweaver, Nvu)
 We are properly positioned for growth once WCMS is standardized.
What the numbers show…
Web/Application Accessibility
Reviews*
713
297
51
71
FY12
FY13
FY14
FY15
 Numbers reflect growth in the
following:
•
ASRB Reviews
•
Application reviews outside of
the ASRB process (e.g.,
classroom)
•
Website Reviews (automated)
•
Website Reviews (manual)
Next Steps
 Build on Pilots!



Web Accessibility Audit (new WCMS!)
Office of Distance Education Office
Document Accessibility
 Improve transparency

Grievance procedures
 Continue to improve campus buy-in


Look at our data (AT assessments, Captioning/Transcription, Web Accessibility, Accessible Text)
Targeted marketing with respect to our services
 Streamline costs

Continue to streamline and drive down per minute captioning/transcription costs
 ITAG v2.0



Strategies for more inclusive classroom practices (UDL)
Identify additional “Choke Points”
Build on Accessibility Liaisons
Recommended First Steps
 Identify your team
 Develop/update accessibility and procurement
policies
 Evaluate website and EIT
 Prioritize remediation
 Publish a grievance process
Contact Information
 Bisi Okubadejo, [email protected], 410-528-
5532
 Assistive Technology Initiative, George Mason
University, [email protected], 703-993-4329
 Office for Civil Rights, [email protected], 1-800-421-3481
 Federal Relay Service: (800) 877-8339 TTY / ASCII
(American Standard Code For Information Interchange);
(877) 877-6280 VCO (Voice Carry Over); (877) 877-8982
Speech-to-Speech; (800) 845-6136 Spanish; (866) 377-8642
Voice; (866) 893-8340 TeleBraille; (800) 877-0996 Customer
Service (Voice/TTY, ASCII and Spanish)