VR and Accessiblity

I've been wondering about accessibility issues with virtual reality (VR), especially since this seems to be the year of VR.  I've not seen any discussion or even hints at accessibility issues in VR, but clearly there are accessibility issues.  

A couple of years ago I had a discussion with a colleague about accessibility in computer gaming.  This was in conjunction with an educational program that taught students to write programs for games.  I started looking for information about accessibility in gaming.  I was introduced to the Games_access mailing list.

In a previous life I'd been working with folks at IGDA (International Game Developers Association). The Games Access folks are a Special Interest Group (SIG) of IDGA.

To subscribe or unsubscribe via the World Wide Web, visit
https://pairlist7.pair.net/mailman/listinfo/games_accessor, via email, send a message with subject or body 'help' to
games_access-request@igda.org You can reach the person managing the list at
games_access-owner@igda.org

I've been on the list now for a couple of years and it's been informative.  There are game designers with disabilities on the list and folks working to make games more accessible.  Some of the discussions they get into are very technical and others much more fitting with my interests.

All this is by way of introducing you to a very interesting blog post by Ian Hamilton about VR and Accessibility on Gamasutra.

It's long and detailed and raises accessibility issues beyond the more commonly identified issues. If you're interested in accessibility issues and VR this is a great read.  It begins:

Virtual reality brings some fantastic opportunities for people with disabilities. New experiences, therapeutic benefits, even accessibility for people who have better head control than hand control. But it also brings considerable new barriers, with great potential to lock people out from these benefits.

Some of the barriers that VR presents are unavoidable, there are people who will simply never be able to take part in VR as it currently exists. From the people who will never be able to overcome simulation sickness, to people who simply aren’t physically able to have a bulky device on their head.

But other barriers are avoidable, through the right design considerations - through accessibility.

It is still early days for this iteration of VR, so this post doesn’t aim to provide all of the answers or form a concrete set of guidelines. There will be issues that are not covered here, and still there’s huge room for innovation, discovering new and better design patterns. 

continue reading this post at:
http://www.gamasutra.com/blogs/IanHamilton/20161031/284491/VR__accessibility.php

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.

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.

Another MOOC in Trouble with the Department of Justice

U.C. Berkeley has been offering public, free MOOCs taught by their faculty.   But, like the MIT/Harvard MOOCs that were identified as problems a year ago, the Berkeley MOOCs were identified as no accessible and two individuals brought their concern to the US Department of Justice.
The story was reported by Inside Higher Education September 20.  Included in the story is a link to the DoJ letter to UC Berkeley.  The first two paragraphs are important for any folks who want to know the legal justification and reason to pay attention to accessibility issues.

The United States Department of Justice (the Department) investigated the University of California at Berkeley (UC Berkeley) under title II of the Americans with Disabilities Act of 1990 (ADA), as amended, 42 U.S.C. §§ 12131-12134, and the regulation implementing the ADA, 28 C.F.R. Part 35. UC Berkeley is a public entity subject to the ADA and its regulation. 42 U.S.C. § 12131(1)(B); 28 C.F.R. § 35.104. The ADA prohibits discrimination against qualified individuals with disabilities by public entities. The Department is authorized to investigate compliance with the ADA and issue findings. 42 U.S.C. § 12133; 28 C.F.R. § 35.172. The Department investigated the accessibility of UC Berkeley’s free audio and video content available to the public on UC Berkeley’s YouTube channel and iTunes U 2 platform as well as its Massive Open Online Courses (MOOCs) offered on the edX learning management platform (UC BerkeleyX); collectively, we refer to audio and video content and MOOCs as “online content.”

The ADA’s nondiscrimination mandate states that no qualified individual with a disability shqall, by reason of such disability, be excluded from participation in or be denied the benefits of services, programs, or activities of a public entity, or be subjected to discrimination by a public entity. 42 U.S.C. § 12132; 28 C.F.R. § 35.130(a). The Department is authorized to file a civil action in federal court if the Attorney General finds a violation of the ADA. 42 U.S.C. § 12133; 28 C.F.R. Part 35, Subpart F. 

UC Berekeley's first response has been to threaten to remove all inaccessible content from their courses, or stop offering the MOOCs.  They have gotten some sympathy in crafting DoJ as the big bad wolf in this situation. Others have no sympathy.  Of course ADA was passed in 1990.

UC Berkeley pointed out that the letter of findings only applies to their free, public MOOCs and not to their credit bearing online courses.  That is true.  The complaint was focused on their public MOOCs.  But, the legal issues, as I have written before, apply to all digital content.  ADA and Section 504 can both be used to cite accessibility problems in the Berkeley online courses and digital that are password protected.

The University of California System, according to the DoJ letter has had an accessiblity policy in place since 2013 which sets "forth technical standards and adopts the Web Content Accessibility Guidelines (WCAG) 2.0 at level AA success criteria."  

And then DoJ states:

While the University of California’s Information Technology Accessibility Policy adopts the WCAG 2.0 AA technical standard, which provides clear parameters for ensuring online content is accessible to individuals with disabilities, UC Berkeley has not ensured compliance with its policy. 

That makes it clear that its not enough to have a policy, there need be actions to ensure compliance. This letter of finding pprovides helpful guidance for academic institutions everywhere in the US.