Monday, January 05, 2015

Two Universities Settle with OCR

The end of the year had a couple of interesting OCR agreements made public.  University of Cincinnati and Youngstown State University both were found to have websites and online courses that were not completely accessible and in violation of federal civil rights legislation.

The findings were of course very similar to other findings reported by OCR against other community colleges and universities.  I'm posting the excerpts from the letter of findings below because there was a comment on a Chronicle article from someone who was asking for more detail: "I have no idea how a website would be less accessible to those with disabilities. Since I occassionally work on a website, I would like to know if I am similarly overlooking an important compliance issue."

Excerpts from the OCR Youngstown State University Letter of Findings
The US Department of Education’s Office for Civil Rights announced an agreement with Youngstown (Ohio) State University to ensure equal access to its websites for individual s with disabilities December 12, 2014.

The following sections have been taken directly from the OCR letter of findings and may be useful in reviewing institutional policies and standards.

Blackboard is a separate system that the IT Department does not work with; it is a “black box” or proprietary system used to deliver online learning, and the University uses it “as is.” IT staff do not create, build, or control the content on that system, and University staff interviewed stated that the University does not actively make sure Blackboard is in compliance with laws such as Section 504 or Title II; rather, a staff member deals with exceptions when things are brought to his attention. In such a case, if a course does not meet accessibility guidelines, the faculty member involved would be contacted

Distance Education Program
The University has developed its own process, known as the “eYSU Rubric Checklist,” for creation of distance education courses. The checklist provides guidelines to faculty for  developing online courses. The final standard required by the eYSU rubric is that “[c]ourse materials are provided in accessible formats.” The rubric states that, “[t]o the extent possible, equivalent alternatives are provided for audio and visual content (a transcript of audio and a transcript or closed captioning for video).” The rubric also states that course creators should consult with the DSO on steps to take to make a course accessible. 

The eYSU guidelines require that course creators use the Distance Education department’s template and that courses applying for re-design are re-worked so that these “incorporate newer technologies to ensure equal access to all.” The eYSU rubric contains links to electronic documents; including links to the University’s accessibility guidelines, web accessibility guidelines, and Section 508 compliance documents. 
The distance education course creation/re-design policy includes requirements that course creators participate in appropriate training as provided by Quality Matters or the YSU Office of Distance Education. Trainings include but are not limited to: eYSU Rubric Training, Apply the Quality Matters Rubric Workshop (required by all developers), and LMS (Blackboard) training.

Distance Learning courses are also required to undergo a Quality Matters (QM) review: a determination of whether the course is accessible to persons with disabilities. This accessibility requirement is cited on the University’s Distance Education website at Included in the 2011-2013 QM guidelines are accessibility standards that require courses to employ accessible technologies and information as to how to obtain accommodations, to contain alternatives to auditory and visual content, to use design that facilitates readability and reduces distractions, and to accommodate the use of assistive technology. 

A University staff member informed OCR that the majority of the time online videos are used for distance learning. The staff member stated that it was not clear if the training for those creating distance learning courses included instructions on how to make videos accessible, but presumably so. 

University staff stated that distance education course creation is done by different departments. Faculty members use the standard course template if they request a distance education course for a term, which includes a statement on disability requirements. An instructional designer on staff, who is trained in accessibility and is also a master reviewer for QM, is available to any faculty member; and the Distance Education department recommends that any faculty member thinking about putting a course online should speak with the instructional designer for guidance. 

University review of distance learning courses is required. The review includes the instructional designer, the content editor for the specific department, and the faculty member who designed  the course. The eYSU rubric has 16 standards, with requirements and guidelines. The QM rubric has 32 standards, some that are required and some that are recommended. Courses have to meet all of the requirements of both, and many of the recommendations/guidelines, to pass review and be approved. Faculty can use the rubric, QM, or both. Faculty members also have to go through training with QM; that training discusses accessibility and how to put courses in an accessible format. 

The Distance Education department offers training to all faculty on how to make material accessible under the eYSU rubric, but the training is not required except for the information about the rubric included during new faculty orientation.

Distance Education staff stated that the IT Department responds to complaints about accessibility that are web-related; if a complaint is course-related, the complaint would probably start with the Distance Education department. For complaints about website inaccessibility, Distance Education defers to IT unless the issue is with Distance Education’s specific web page. Distance Education staff stated that the Distance Education department monitors its own site; its web editor and the instructional designer are responsible for making sure that the campus accessibility policies are implemented. All of the department’s web pages and courses are created and then reviewed before these go live. An OCR review of the Distance Education website demonstrated that, nonetheless, many links included on that page lead to documents that exhibit inaccessible features.

Thursday, November 13, 2014

The Access and Equity for All Learners in Blended and Online Education is Now Available.

Access and Equity for All Learners in Blended and Online Education is now available as a PDF on the iNACOL site.   Spread the word.

Wednesday, November 12, 2014

It's Out, Almost.

Well, it got a limited printing just in time for my presentation at the iNACOL Symposium on Blended and Online Learning.   When I say "just in time" I mean it.  It was actually printed in Palm Springs site of the Symposium.  I think they only printed two boxes.  That was all I saw.   I got to hand them out at my session however, and the rest were put on a resource table.

The link to the file should be posted on the iNACOL website this week.  When it is up, I'll post it here.

The feedback I heard about on my session was all positive.   The slides, similar (but better) than the set I used this summer are  below.

Wednesday, September 17, 2014

Do the Funders Know the Online Accessibility Requirements?

I was invited to participate in a symposium at Harvard in November.  This is a follow-up to a similar event about a decade ago resulting in the publication of Dede’s Online Professional Development for Teachers – Emerging Models and Methods (2006).

I had made it clear that I've not been doing online teacher professional development lately.  That I was currently more focused on issues of access and equity in online education.  I even recommended some other folks currently doing more with oTPD (online Teacher Professional Development).  But, they invited me anyway.

I was asked to write a piece for discussion.  It was interesting to go back to the online teacher professional development project and my attempts to bring more accessibility to our online courses. The laws haven't changed much over the past decade, but our understanding of what access is, and the enforcement has changed.

One thing I was thinking about though, was that at the time, the program officers never mentioned access.  I don't think it was on their radar screen.  Clearly, every grant that's funded by either ED or NSF carries with it agreements to meet applicable civil right legislation.  

I asked, in my paper, if the oTPD programs that exist today are meeting their accessibility obligations, and if the funders are asking.

I'll post more about the reaction to my paper, after the event.