when the doj/ocr makes a visit: lessons learned in resolving complaints about inaccessible it
TRANSCRIPT
When the DOJ/OCR Makes a Visit: Lessons Learned in Resolving Complaints About Inaccessible IT
www.3playmedia.comtwitter: @3playmedia
#a11y
Type questions in the window during the presentation This presentation is being recorded and will be available for replay To view live captions, please follow the link in the chat window
Sheryl BurgstahlerDirector, Accessible Technology Services
University of Washington
Dan JonesChief Digital
Accessibility OfficerUniversity of Colorado
Boulder
Janet SedgleyManager, Accessible Technology ServicesUniversity of Montana
Lily Bond (Moderator)3Play Media
OLC Workshops of Interest to You
• Special discounts available for OLC Members!
April 13 – 15, 2016 - Designing with Accessibility in Mind – 3 Day Workshop
http://onlinelearningconsortium.org/learn/workshops
When the DoJ/OCR Makes a Visit: Campus Leaders Discuss Lessons
Learned in Resolving Complaints About Inaccessible IT
> Sheryl Burgstahler, University of Washington> Dan Jones, University of Colorado Boulder> Janet Sedgley, University of Montana
What do they have in common?
University of Cincinnati • Youngstown State University • University of Colorado-Boulder •
University of Montana-Missoula • UC Berkeley • South Carolina Technical College System • Louisiana Tech University • MIT • Maricopa Community College District • Florida State
University • CSU Fullerton • California Community Colleges • Ohio State University: University of
Kentucky • Harvard University
www.uw.edu/accessibility/requirements/
What is the legal basis?
>Section 504 of the Rehabilitation Act>The Americans with Disabilities Act & its
2008 Amendments>State & local laws
But what if laws don’t specifically mention IT?
Consider ability on a continuum
seehearwalk
read printwrite with pen or pencilcommunicate verbally
tune out distractionlearn
manage physical/mental health
Definition of “accessible”
“Accessible” means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, & enjoy the same services as a person without a disability in an equally effective & equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally & independently as a person without a disability.
Approaches to access:
> Accommodations> Universal design
Both are important!
Universal design =
“the design of products & environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.”
The Center for Universal Designwww.design.ncsu.edu/cud
Uncaptioned video
Captioned video
Interpreter for deaf student
UD on a continuum
Key aspects of UW approach(without civil rights complaint)
> Promote accessibility within context of universal design, civil rights, & inclusive campus culture
> With UW-IT’s Accessible Technology Services as lead, resource, catalyst, & community-builder: – support efforts of Disability Resources for Students– develop & evolve “ideal state” & gap analyses– create list of IT products developed, procured & used,
prioritize, determine strategy, assign staff– lead a top-level IT accessibility task force with key
stakeholders, clear direction, regular reports
Key aspects of UW approach
> With UW-IT’s Accessible Technology Services as lead, resource, catalyst, & community-builder, cont.: – develop partnerships & empower stakeholders within
their roles in a distributed computing environment– provide guidance on an IT accessibility website– develop IT accessibility guidelines & standards– offer training & consultation, support user group– host captioning parties, meetings with Hadi, & other
events– proactively test websites, PDFs & offer remediation
University of Montana timeline(with civil rights complaint)
> An OCR complaint was filed against UM in the spring of 2012.
> UM formed the EITA Task Force to help draft a UM policy & coordinate necessary support activities.
> March 7, 2014: UM signed a resolution agreement with the Department of Education Office for Civil Rights.
> UM provided 15 specific reports to the US Department of Education, related to areas such as web accessibility, classroom IT, & grievance processes.
> March 2016: UM provided a full report documenting how UM has met required remediation action in the agreement that have not already been met.
UM resolution agreement (with US Department of Education Office for Civil Rights, March 2014)
> Include accessibility requirements in all IT procurement > Survey current & former students about their
experiences with barriers due to inaccessible IT at UM> Perform an accessibility audit of all IT on campus> Create a remediation plan based on results of the audit> Ensure document & web accessibility by the end of the
year
Key aspects of UM approach
> Teamwork with existing partnerships> Active partnership with LMS vendor> Top down / bottom up approaches> Consistent message linked to accessibility site> Building relationships> Building on existing processes> Formalizing involvement> Support from key leaders
University of Colorado Boulder response timeline (with US Department of Education Office for Civil Rights)
> Initial accessibility study in 2013> DoJ inquiry in Spring 2014> Response & project formed in May 2014 (3-5
year project)OIT, Disability Services (part of ODECE – Office of Diversity, Equity, & Community Engagement), Legal, Procurement, many others
> Investigation Closed May 18, 2015
UC Boulder response
> Scope of work defined, resources identified, & teams formed (May 2014)
> Project focal areas (June 2014)• Policy and exceptions process• Application and technical services
remediation• Accessibility support services• Communication & documentation
UC Boulder lessons learned
> Leadership commitment
> Transparency with DoJ & community
> Active engagement with community members who have a disability
> Leveraging third parties for consultation & audits
> Continuing engagement with community
> Ensuring wide publication of accessibility issue reporting process
Overall lessons learned
> Get commitment of leadership & key organizations, develop organizational structure with stakeholders
> Identify key IT developed, procured, & used (websites, PDFs, videos, LMSs, ATMs, software) & develop – priorities – corrective action strategies & assignments– regular reports
> Create & disseminate policies/guidelines/standards > Provide resources, training, promotional activities> Develop procurement policies & procedures> Develop & publicize grievance procedure
Who should be involved?> President, academic affairs, provost, deans, dept chairs> Academic senate, college council, council of chairs…> Student affairs> Students> Central campus IT unit> Outreach units> Libraries> Online learning programs> ADA compliance officer> Procurement
It’s not just disability support services!
Questions
> What partnerships on & off campus can you develop to support the IT accessibility goal?
> How can we get support from administrators?
> What are the best sources for providing guidance to your campus on concrete steps toward more accessible IT?
Q&A
Upcoming Webinars: Feb 25: 10 Tips for Implementing Accessible Online
Media
Mar 10: Quick Start to Captioning
Mar 17: Quick Start to Video Search
Mar 31: The Legal Year in Review: Digital Access Cases
You can register for our free webinars at: www.3playmedia.com/webinars/
Panelist Contact Info
Sheryl BurgstahlerUniversity of [email protected]
Dan JonesUniversity of Colorado [email protected]
Janet SedgleyUniversity of [email protected]
Lily Bond3Play [email protected]
Please type your questions into the window in your control panel. A recording of this webinar will be
available for replay.