- Judy Ruttenberg, ,Program Director ARL
- Jonathan Lazar, Prof. of Computer and Info Sciences, Towson University
- Sheryl Burgstahler, Founder and Director, DO-IT Center, U of Washington
Joan Lippincott and Cliff Lynch solicited this presentation; ARL put it together. ARL is committed to accessibility, both in terms of digitized and born digital content. More than 79% of ARL materials budgets are spent on e-resources, and that does not account for digitization, institutional repositories or digital publishing. They developed the ARL Accessibility Toolkit.
Sheryl of UW noted that in the past few years, 14 higher education institutions have been sued, for their IT not being accessible; this includes Harvard, MIT, Penn State, and U of Cincinnati. The more we make our resources available to everyone, the more at risk we are for legal complaints.
- Section 504 of the Rehab Act
- The Americans with Disabilities Act and its 2008 amendments
- State and local laws
We need to consider all abilities on a continuum from fully able to totally unable. Handicaps can impact the ability to see, hear, walk, read print, write with pen or pencil, communicate verbally, tune out distraction, learn, and manage physical/mental health.
The definition of “accessible” in terms of IT means that we must provide the same information, same interactions, and same services in an equally effective and equally integrated manner, with substantially equivalent eases of use. Disabled people must be able to obtain info as fully, equally, and independently as a person without a disability.
Lessons learned from legal cases include:
- Conduct accessibility audits and develop corrective action strategy
- Develop and disseminate accessible IT policy
- Set and disseminate IT Accessibility standards
- Provide training & education
- Develop procurement policies and procedures!!! Include language for vendors asking “what are your future plans for incorporating accessibility?” We are responsible for buying the product; the vendor is not at risk, so will not support accessibility without pressure.
- Develop and publicize a grievance procedure which is very public, not just a help link. You want patrons to have their grievance addressed before they take it to legal entities.
- Address developed, procured and used IT: websites, learning management systems, classroom technologies, banks and ATMs, purchased software
There are 2 basic approaches to developing accessibility: accommodations and universal design. Both are important. Universal design means it was designed for usability by all, without the need for adaptation or specialized design (this also is on a continuum).
Key aspects of the UW approach:
- Promote accessibility within the context of universal design, civil rights, and inclusive culture
- Develop and evolve “ideal state” and gap analyses
- Lead a top-level IT accessibility task force with key stakeholders, clear direction, and regular reports
- With UW-IT’s Accessible IT Services as leader, resource, catalyst, and community-builder, develop partnerships and empower stakeholders within their roles in a distributed computing environment
- Provide guidance on an IT accessibility website
- See their website for info on what the solutions are for various problems
Univ. of Montana Settlement Agreement with US Dept. of Ed. Office for Civil Rights March 2014 included far more than what was required by law:
- Include accessibility requirements in all IT procurement
- Survey current and former students about their experiences with barriers due to inaccessible IT at UM
- Perform an accessibility audit of all IT on campus (most only test a sampling)
- Create a remediation plan based on results of the audit
- Provide 15 specific reports to the US Department of Ed, related to areas such as web accessibility, classroom IT, and grievance processes
- Provide a full report, due in March 2016, documenting how UM has met every required remediation action in the agreement
These settlement requirements are far beyond the requirements of the law, which encourages others to be ahead of the game. These are predictable things; we just don’t know who will be sued next.
It’s not just student-facing procurement, it’s all procurement. That’s difficult, as it includes even software required by a faculty member. Always ask vendors for a VPAT: a Voluntary Product Accessibility Template. Vendors lie.
Ohio state tests the interfaces and if they don’t meet what the vendor promised, they make the vendor sign an indemnification statement, so Ohio State can’t be sued – the vendor would be.
Put vendors on notice: give them deadlines to make things accessible, or stop use. Pressure on vendors is very important. The Universities are the ones at risk.
One institution’s approach is to agree only to one year conditional use and if not accessible by the end of the year, may not resubscribe.
Have a plan and a clear timeline, so you can show you’re working on it, if a legal issue arises.
Campus IT Accessibility Plan:
- 6 months: complete campus/school accessibility audit
- 9 months: ensure that IT procurement and purchasing processes include accessibility
- 12 months: ensure that major web pages are accessible
- 15 months: goal to have 95% of course content online accessible
- 18 months: major online student processes (admissions, registration, payment, graduation) are all accessible.
Start small with faculty syllabi!! Use Word format and make sure all graphics are CAD.
Be transparent about progress:
- Provide monthly, publicly-posted reports comparing academic departments and how compliant they are
- Publicly state the progress on the campus wide accessibility plan
- Include accessibility as a part of new faculty/staff training
- Have an accessibility statement on all university web pages
It’s a process.
Who should be involved?
- Academic affairs, provost, deans, department chairs
- Academic senate, college council, council of chairs
- Student affairs
- Central campus IT unit
- Business outreach units
- Online learning programs
- ADA compliance officer
It’s not just disability support services!
- This is not about lowering academic standards
- This is not an academic freedom issue, it’s a civil rights issue
- Faculty have legal responsibilities to ensure access to students with disabilities
- Begin with a syllabus that sets out clear expectations
- Encourage students to talk to you about their learning and accessibility challenges
- Use support services to help you make this happen. If they are not currently there, advocate for them.
Those accommodations letters from office of disability make it a legal issue.
Focus on the positive:
- For instance, accessible PDFs help ALL students search for information (searchable)
- Remind stakeholders of the penalties for non-compliance, but…
- Remind Deans and Chairs that compliance is something good that can be included on:
- Their departmental/dean annual reports
- Accreditation reports,
- Reports to state government
- How can faculty get CREDIT for doing a good job?
- Faculty annual reports? Promotion and tenure applications? But be careful to respect faculty governance.
Example of a no-cost idea: Require that when any grant proposals are submitted to federal agencies for student development or education materials or infrastructure, that there be a specific budget for IT accessibility. This raises awareness early in the process, and also, if the grant is awarded, PIs cannot say there is no funding for making materials accessible. This could easily be enforced by some universities.
Questions and Answers:
Someone noted that CLIR’s hidden collections program won’t pay for transcription. Helen from Mellon, the funding agency, said this year is an experimental year. Someone asked for it to be included in the grant proposal guidelines. Helen said it’s on Mellon’s agenda.
Very often inaccessibility happens by accident. No one thought about it. Planning is the way to make accessibility happen.
What about IRs with a self-submission model? We have no control over what faculty submit. We can only make available what we are given. Suggestion: we could start by providing info on how to make content accessible, and put it into the deposit information, and then have liaisons work with the faculty to educate them.
In a professional org, ACM, the SIG-CHI (Special Interest Group for Computer Human Interaction) wanted more accessible submissions in the ACM digital library. They require PDF format. For every submission, they run each PDF through testing, and provide feedback before final submission; this raised accessibility 20%. Over time they may change that model.
What about communication with students – emails, social media, etc. How accessible do these things need to be?
Answer: Email is generally accessible if they have the right client. Attachments and embedded images are issues. Repeat the basic info of the attachment within the email, and provide links to websites instead of attachments.