Lessons and Pitfalls on Campus Accessibility, University of Montana

April 15-17, 2015

Presented byAmy F. Capolupo, LCSW

Director, Disability Services for Students, University of Montana

Janet Sedgley, Ph.D.Electronic and Information Technology Accessibility CoordinatorManager, Accessible Technology Services, University of Montana

April 15-17, 2015

Timeline of UM’s OCR complaint

• May 2012 –Alliance for Disability and Students at the University of Montana (ADSUM) filed the complaint.• August 2012- UM received the complaint. • September 2012- EITA Taskforce formed by legal counsel. • October 2012 Civil Suit filed by student – represented by the NFB. • November 2012-2013- Multiple visits with NFB resulting in joint

settlement. • March 2014 Resolution Agreement signed.

OCR Complaint alleged the following: • Inaccessible class assignments and materials on the learning

management’s system• Inaccessible live chat and discussion board functions in the learning

management system• Inaccessible documents that are scanned images on webpages and

websites• Inaccessible videos in flash format, which are not captioned• Inaccessible course registration through the website Cyber Bear• Inaccessible classroom clickers

Set of assumptions pre and post complaint • The SWD has to request the

modification for accessible text and is responsible for knowing how to trouble-shoot accessibility• Captioning for all non-front facing

video material will be provided to students via a request. • Having an accessibility clause in

software procurement is a standard practice and is sufficient to ensure access.

• The SWD has a right to an accessible environment. All documents and websites must be accessible without additional modification. • All videos used for educational

reasons must be captioned. • All software procured on the UM

campus must be evaluated for accessibility prior to implementation.

Knowing your Institution’s Commitment• Campus climate• Budget • Institutional buy-in

Possible Framework to address EITA access on your campus.

meaning

context

powerhistory

possibility

Finn, J., & Jacobson, M. (2003). Imagining Social Work and Social Justice. In Just practice: A social justice approach to social work (pp. 22-44). Peosta, Iowa: Eddie Bowers Pub.

The “meaning” of Accessibility

“Accessible” means that 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, with substantially equivalent ease of use.

University of Montana

“Context” for Accessibility on your campus • The U.S. Department of Education, Office for Civil Rights (OCR) enforces Section 504 of the

Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act of 1990 and the regulations that implement those statutes at 34 C.F.R. Part 104 and 28 C.F.R. Part 35. These laws prohibit discrimination on the basis of disability in programs and activities receiving federal financial assistance from the U.S. Department of Education and by public entities. The University receives federal financial assistance from the U.S. Department of Education, is a public entity, and is, therefore, subject to the requirements of these laws.

• The OCR received a complaint of disability discrimination against the University of Montana on May 4, 2012 (OCR Reference No. 10122118). The complaint alleged that the University is discriminating against students with disabilities by using inaccessible electronic and information technology, including: inaccessible class assignments and materials on the learning management system, Moodle; inaccessible live chat and discussion board functions in the learning management system, Moodle; inaccessible documents that are scanned images on webpages and websites; inaccessible videos in Flash format, that are not captioned; inaccessible library database materials; inaccessible course registration through a website, Cyber Bear; and inaccessible classroom clickers.

Scope of Power regarding Accessibility • By May 1, 2014, the University shall implement, as part of its request

processing a proposal, a requirement that bidders meet the accessibility standards of WCAG 2.0 Level AA for web-based technology.• By March 14, 2014, the University shall provide and make readily

available to faculty and staff, information about their obligations to ensure EIT accessibility and also provide resources to assist in meeting those obligations.• By March 14, 2014, the University will establish a University website

that will be dedicated to accessibility, and that will provide tools and information for training.

History of Accessibility

• Disability Services for Students ensures that programs at the University of Montana are accessible and usable by students with disabilities. Access is a civil right; therefore, reasonable modifications must be made. We recognize that a “one-size-fits-all” approach is not a sound response to students with disabilities who are seeking to ensure appropriate modifications. Therefore, our staff works with each student individually and modifications are provided on a case-by-case basis.

The Possibilities of EITA on your campus • Dr. Marc Maurer, President of the National Federation of the Blind, said: “While complaints by

individual students and legal actions can incrementally improve access to higher education, there is no substitute for comprehensive and effective policies that are implemented and enforced at the highest levels by university administrations. This agreement, which is the most comprehensive of its kind to date, represents a thorough and systematic approach that will benefit University of Montana students for years to come and serve as a model for university policies and practices across the nation. We applaud the University of Montana for the extraordinary commitment that it is making to ensure that all of its students, including those who are blind or who have other disabilities, receive the equal education that the law demands and the full benefit of the college experience that the university provides. We also applaud the work of the Office for Civil Rights, which has crafted this agreement with extensive input from the National Federation of the Blind and which will work with the university to ensure its full implementation.”

• Significant increase in deaf or hard-of-hearing students on our campus• Noticeable shift in who is using services at DSS.

Pragmatics

• A bit about me (or What is an IT person doing here!)• Clarity about my biases:• Floundering in the messiness so that campus community doesn’t have to.• Thinking in continuums while presenting more black and white.• Low hanging fruit.• Provide needed support.• Working with stages.

Roadblocks and unforeseen difficultiesOur policy covers:• Web.• Documents.• Instructional Materials & environments.• Media.• Software / Hardware (Procurement).

Approach

• Stage 1:• Explore / Evaluate.• Establish targets.

• Stage 2: Enable / Implement:• Perspectives.• Products.• Processes.• People.

• Stage 3: Embed

Web

• Establishing standards and perspectives.• WCAG 2.0 AA.• Keeping web pages accessible.

• Products: CMSs and templates for sites.• Processes: • Certification.• Monitoring.

• People: Who needs to be involved:• Web designers.• Web content providers.

Documents – Standards

• Straight text* documents created at UM should be text-based and have:• sequential heading styles,• lists that are styles and• descriptive links.

• Straight text* documents that are acquired from other sources should be, at a minimum:• text-based with• heading styles provided by the UM convertdoc document conversion processes.

• Recommendation for images: Documents, even acquired ones, that are used frequently or on publically-facing websites should be evaluated and alternative text descriptions provided for images with significance or meaning. This is at the professor's discretion for course materials.• *Straight text excludes STEM topics and documents with extensive images

Documents - Perspectives

• Different kinds of .pdfs.• Distinctions about where these documents are found (handed out in

class, shared through an LMS or hanging off of websites.• Images (a large related issue).

Documents

• Products• Convertdoc (ABBYY FineReader).

• Processes• Syllabi.• Distinctions .• Who does this, how, and to what level.

• People• In departments or centralized.• Not a “typing service” but remediation.

Instructional Materials / Environments

• Establishing standards• Online – Web standards.• Classrooms – perspectives.

• Products• L:MS features • Accessible equipment and software.

• Processes• Keeping software updated.• Keeping faculty informed.

• People

Media

• Establishing standards and perspectives• DCMP standards.• YouTube captioning?

• Products• DocSoft / Dragon Naturally Speaking.

• Processes• Live captioning.• Full captioning support / Partial support .

• People• It’s weird to hear myself.• But what if I find a good video at midnight?

Software / Hardware

• Establishing standards and perspectives• WCAG 2.0 & 508.

• Products• ???

• Processes• Procurement takes long enough as it is.• You are going to tell me what I can use on my own computer?

• People• Strong advocate needed.• IT Senate focusing on Enterprise applications.

Procurement

• Establishing standards and perspectives• Fine tuning.• Political distinctions.

• Products• Reports.

• Processes• Exceptions process.• Oversight process.

• People• Several lynchpins.

Touchy subjects

• Math.• Extensive images.• Copyright

Communication

• Should have included base groups earlier (but they weren’t interested).• Should have worked more with collaboration for a communication

plan.• Should have differentiated between training and communication plan.

Costs:

• Web.• Documents.• IM Environments.• Media.• Software / Hardware.• Procurement.

Your plan

• Exercise 1: Use the principles of meaning, context, power, history and possibility to create a mission and guiding principles for your campus.

• Exercise 2: Apply the mission and guiding principles to flesh out the stages for your campus addressing what and how.