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
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 http://web.ysu.edu/gen/ysu/Quality_Matters_m3899.html. 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.
