Thursday, October 27, 2016

What Accessibility Training Does Your Institution Provide?

This is the second in a series of posts analyzing the Dudley v Miami Consent Decree.    

Accessibility Training

The Department of Justice (DOJ) gives the institution 6 months to provide mandatory accessible technology training to all employees responsible for: 
  • content on the institution’s websites; 
  • providing support for educational technology; 
  • procurement of educational or digital technology; 
  • converting materials into accessible formats.  
And, includes training for employees in Student Disability Services, and the Office of Equity and Equal Opportunity.  Also included in the training will be academic technology specialists from every college, school, and library as well as the person in HR responsible for ADA compliance.

In addition, the institution is required to provide training to all faculty and their administrative assistants.  Teaching assistants and student assistants also get trained if they help in any course with at least one student registered with Student Disability Services, or if they are hired to provide accommodations to students with disabilities.
That’s pretty comprehensive.  Anyone that has something to do with student learning.

Once all this training has taken place, the institution is not done.  It will need to provide training for all new hires that fall into one of the roles identified.

This is DoJ looking at ADA compliance. The Department of Education’s Office for Civil Rights (OCR) deals with Section 504 compliance.  While there is overlap between the laws, there are also differences which play out in differences in recommendations/requirements.  Only about a third of students with disabilities self-disclose to the disability services office, so OCR has taken the position that digital materials need to be accessible even if there’s not a student known to disability services in the course.  DoJ is looking at more than just online accessibility, they expect the training to look at all potential technology barriers.

A more detailed discussion about the focus of the training will be in an upcoming post.

If your institution is not providing accessibility training to all the employees, you should be developing that training plan now.

Looking for help designing and/or providing that training, let me know. I can help.

Tuesday, October 25, 2016

Do You Have (or Need) An Accessible Technology Coordinator?

What is an Accessible Technology Coordinator?  According to the US Department of Justice (DoJ) in a recent Consent Decree with Miami (of Ohio) University required the creation of an Accessible Technology Coordinator (ATC), who reports directly to the Vice President for Information Technology. 

In the Consent Decree DoJ specified that the ATC will be knowledgeable concerning:
  1. The general requirements of Title II of the ADA and its applicable regulation;
  2. Accessibility and usability of web content;
  3. Accessibility and usability of technology, including equipment and devices used in classrooms and laboratories (e.g., clickers, lab equipment, smart boards);
  4. Testing and evaluation of the accessibility of web and other technologies;
  5. The W3C's WCAG 2.0, ATAG 2.0, UAAG 1.0, WAI-ARIA 1.0, MathML, WCAG2ICT, and any successors to those standards
  6. DAISY and EPUB 3. (Open Accessible Standards for publishing)

And the ATC will be familiar with:
  1. Accessible document development and remediation; and
  2. The appropriate provision of auxiliary aids and services for students with disabilities in non-electronic or non-digital formats, such as Braille hard copy, tactile graphics, large print hard copy, sign language interpretation, and reasonable modifications to policies, practices, and procedures, such as procuring technologies outside of general policies and making reasonable security exceptions for assistive technologies.

In addition the ATC will make quarterly reports to the Vice President for Information Technology and the Office of Equity and Equal Opportunity.
As if that’s not enough, the Accessibility Technology Coordinator will also serve on the University Accessibility Committee to be chaired by the Vice President for Information Technology.  The Committee will meet at least quarterly and will include the Web Accessibility Coordinator, the Accessibility Technology Specialist (positions created in the Consent Decree) and representatives from ten departments across the university.
Now you know what the Accessible Technology Coordinator is and what DoJ has created for a position description.  Do you have the need for an ATC?  Are you in full compliance with ADA Title II?
The Consent Decree, can be provide guidance for all academic institutions that need to meet Title II of the ADA (that's most academic institutions)  as well as governmental agencies and businesses that have a web presence.
There is a lot more in the Consent Decree including creation and promulgation of an Accessible Technology Policy; training of employees; creation of a procurement process for software and web technology to ensure those products are accessible.
The full document runs 56 pages, but only about 32 of them provide guidance specifically for academic institutions on what they should consider doing to meet Title II of the Americans with Disabilities Act of 1990 and amendments. 
I’ll cover other aspects of this Consent Decree in future posts.