Wednesday, November 09, 2016

Accessibility Training Required by OCR and DoJ in Consent Decree and Resolution Letters

I promised to get back to this topic a week or so ago.  This post provides academic institutions with guidance on the content of accessibility training they should be providing.

Before I started writing this post I found another set of accessibility findings. The Region X Office for Civil Rights had and interesting announcement earlier this year.  They reportedly received complaints involving access to websites at 11 different education organizations.  OCR cited Section 504 and Title II of the ADA in each letter. Each of the 11 parties, including two state education agencies, and 9 K-12 organizations settled (resolved complaint) before OCR completed their investigation.

Each of the organization's main website, and at least a couple of additional pages were cited because the sites used graphics without alternative text tags. (The easiest thing to check.)   I believe that by settling before OCR completed their investigation, the institutions avoided more detailed findings. I've said right along, settle as soon as you can.

As a part of the settlements, each of the organizations is required to provide "training on website accessibility for all appropriate personnel." That is all the detail that is in the letters and the letters are all basically the same.

The Department of Justice (DoJ) on the other hand, in the Dudley v Miami Consent Decree was much more specific about the content of the accessibility training.  I've previously posted the list of folks DoJ wanted trained.  The training topics include:

  • the required Accessible Technology Policy which is spelled out in detail in the Consent Decree
  • identity and responsibilities of: 
    • University Accessibility Committee
    • Accessible Technology Coordinator
    • Web Accessibility Coordinator
    • Accessible Technology Specialist
    • personnel in Student Disability Services
  • common assistive technologies used by individuals with disabilities interacting with computers, website, and tools used for learning in and out of the classroom
  • common technological accessibility barriers
  • common methods, resources, etc. for ensuring accessible documents
  • Overview of accepted accessibility standards including 
    • WCAG 2.0 
    • UAAG 1.0
    • MathML
    • DAISY
    • EPUB3
    • BANA 
    • and others
  • consideration of the selection of course texts that have accessible electronic formats
  • the process for requesting and receiving accommodations
  • resources, support, and time frame to deliver accessible converted materials
  • guidance for creating accessible documents
And that's most but not every item included in DoJ's requirements.

Does your institution provide accessibility training, and does it include all the topics DoJ required of Miami?

According to their website, Miami has almost 19,000 students; offers 120 bachelor's, 60 master's, and 13 doctoral degrees. I was unable to determine how many faculty and staff are employed there.