Background: Legal Requirements
State and Federal regulations require equal access to resources and materials for students who are otherwise qualified to enroll courses and specify that accessibility must be built into all learning environments regardless of the mode of delivery (i.e. online or face-to-face). The Office of Civil Rights (OCR) states that a university can violate its obligations under the Americans with Disabilities Act (ADA) when it responds only on an as needed basis to individual requests for accommodations. Face-to-face, online, or web-based course instruction must result in a course-taking experience that is comparable to students without disabilities. Additionally, these same standards must apply to all students using university systems including the USF website and portal.
Applicable legislation to any college/university that receives federal funding includes:
- The Americans with Disabilities Act of 1990 (ADA) as amended, which prohibits discrimination on the basis of disability.
- Section 504 of the Rehabilitation Act of 1973 (P.L. § 93-112) as amended (P.L. 93-16), which ensures that federally funded institutions such as universities provide equal access to all services and programs, with or without accommodations.
- Section 508 of the Rehabilitation Act Amendments of 1998 as amended, which requires electronic and information technology to be accessible to persons with disabilities.
Measurement Frameworks for Assessing Quality Online Courses
- Quality Online Course Initiative (QOCI) Rubric, Illinois Online Network (ION), University of Illinois. The QOCI indicates that an accessible course demonstrates or exceeds the following:
- A text equivalent for every non-text element is provided (e.g. Alt Text, Transcripts, etc.)
- Captioning options is available for audio portions of multimedia presentations.
- Redundant text links are provided for links embedded on server-side image maps.
- Information conveyed with color is also available without color.
- When a Web page requires that an applet, plug-in, or other application be present on the client system to interpret page content, the page provides a link to the needed plug-in or applet.
- When a timed response is required, the user is alerted and given time to indicate that more time is required.
- Row and column headers are identified in data tables.
- Quality Matters Rubric. This rubric indicates that a course that demonstrates a commitment to accessibility includes the following:
- The course employs accessible technologies and provides guidance on how to obtain accommodation.
- The course design facilitates readability and minimizes distractions.
- The course contains equivalent alternatives to auditory and visual content.
- The course design accommodates the use of assistive technologies.
- The Sloan Consortium – A Quality Scorecard for the Administration of Online Education Programs. This tool includes a “Course Structure” section that states that a course adequately addresses the needs of students with disabilities when the course provides alternative instructional strategies and/or the course makes referrals to special institutional resources.
This section describes the goals and guidelines for implementing the USF Accessibility Policy. Click the links below to read each component.
It is the goal of the University of St. Francis that all course material and web- based information is as accessible as possible to all students. The purpose of the Accessibility Policy is to provide guidelines regarding the proactive design and development of robust websites and courses, regardless of modality, in a format that is easily accessible to all students. By making courses and websites accessible to all students, all content is accessible to students with a wide range of disabilities.
Frey, B. A., Kearns, L. R., & King, D. K. (2012). Quality Matters: Template for an accessibility policy for online courses. Retrieved from http://www.qmprogram.org/template-accessibility-policy-online-courses.
Courses in development, regardless of modality, course management systems, or any online presence (website, portal, etc.) for the University of St. Francis will abide by accessibility guidelines. This policy applies to all faculty and staff developing courses. All course delivery mechanisms, course content, and software that are purchased and utilized for a course should be evaluated first for accessibility and also be made as accessible as possible. Course delivery platforms and software that is not accessible must be cleared for purchase by the Accessibility Committee.
USF, as a community, works in a cooperative effort to provide equal access for all students, including students with disabilities. While the university strives to accommodate students as fully as possible, reasonable academic adjustments or accommodations do not include measures which fundamentally alter the academic programs of the university.
To ensure accessible course and website content, the university will follow the practices defined in the World Wide Web Consortium (W3C): Web Content Accessibility Guidelines – Version 2 (WCAG 2.0) Level A. This set of guidelines is most inclusive and covers the key practices followed in the alternate guidelines below:
- Section 508 of the Rehabilitation Act of 1973 (amended 1998). Including the upcoming rewrites (proposed 2011)
- Illinois Information Technology Accessibility Act – Implementation Guidelines for Web-Based Information and Applications 1.0
These guidelines apply to all academic course content both created internally or referenced externally, all USF web presences including the USF website and portal, all resources used in conjunction with instruction including the library, ebooks, databases, and publisher services. Additionally, these guidelines are modality agnostic.
Example WCAG2.0 Level A Guidelines from the Web Content Accessibility Guidelines Website
(Note: This list is illustrative and not complete)
Upon implementation of the Policy, all syllabi should contain the following statements regarding accessible course content.
1. The University of St. Francis is committed to ensuring the full participation of all students in its programs, regardless of the course format. If you have a documented disability and need a reasonable accommodation to participate in this course, complete course requirements, or benefit from the University’s programs or services, please contact the Office of Disability Services (ODS) as soon as possible at 815-740-3204 or firstname.lastname@example.org. The Office of Disability Services is located on the second floor of the LaVerne and Dorothy Brown Library building in room L214. Consultations are also available. Please contact ODS for an appointment.
2. Effective upon completion of an accessibility audit and adjustment based on the results of the audit, all USF web presences should include an accessibility compliance statement. This statement will be linked from the footer of the main website page or from the help menu.-Have W3C logo on main page under “Your Right to Know”
3. As of June 1, 2015, all new course development and digital content will comply with the Accessibility policy.
4. Accessible computer stations will be made available in each computer lab on campus. Each computer lab will have at least one computer station that includes a basic AT package and instructions on how to utilize the software/programs. In addition, the committee will provide a Portable Assistive Technologies Lab (PATlab).
Basic AT package installed fall 2014:
-NVDA (free screen reader for Microsoft Windows)
-Adobe professional (has PDF reader; allows hard copy enlargement)
-Natural Reader (free e-text reader)
-AMIS (free DAISY reader)
-Central Access Reader (CAR) to assist with reading math and logic equations
5. The Accessibility Committee includes representation from each college, IT, CETLA, ODS, Library, and Marketing Services. The committee is charged with the implementation and future revision of the policy, and recommending the prioritization for existing courses for accessibility review, beginning with courses where students are known to have need.
Training will be a critical component to the implementation of the accessibility policy. The training needs for the administration, faculty, and staff of the university and the development and delivery of training materials will require collaboration between the Center for Excellence in Teaching, Learning & Assessment and the Office of Disability Services.
The Center for Excellence in Teaching, Learning & Assessment will (within capacity) offer the following services to assist faculty in the implementation of the policy:
- Accessibility review services for existing courses and external tools/sites used within courses.
- Transcription of audio files and captioning of videos created in courses. Note: Videos selected for use within courses but not created by the faculty or university should be selected in part for the availability of captions. Training will be provided in selecting accessible materials.
Captioning will be provided via three means:
- AST – Captionsynch – Fee based service. Currently licensed at ~2000/yr. Includes 6000 shared minutes through a consortium agreement with South Metropolitan Higher Education Consortium. Price at education retail cost of $2.65 per minute.
- YouTube – Has an automatic caption service. Does require manual editing to insure proper translation of speech to text.
- Amara – This is the manual captioning system in Canvas.
3. Development and maintenance of a support website with guidelines for developing accessible course material