Why must online courses and web-based instructional materials be made accessible to students with disabilities?
SRJC must comply with the provisions of the August 1999 Distance Education: Access Guidelines for Students with Disabilities, the 2008 Chancellor’s Office Distance Education Guidelines (2008), and Section 508 of the Federal Rehabilitation Act (1998) and the Americans with Disabilities Act (1990, amended 2008) to ensure the accessibility of SRJC online courses to all students, including students with disabilities. The Chancellor’s Office requires compliance immediately, and our legal counsel has also advised us to come into compliance with the law. These mandates have been incorporated into the new Board Policy 3.12.3 and Procedure 3.12.3P “Accessibility of Online and Web-Based Instructional Materials,” July 14, 2009. (To view the PDF documents, you may need to download the free Adobe Acrobat Reader).
Why do courses have to be made accessible from the outset? Why can’t we just provide a reasonable accommodation to those students who need it?
In the opinion of the Chancellor’s office, and in compliance with the Americans with Disabilities Act, online courses must be available “any time, any place” for students with disabilities, just as they are for students without disabilities. The guideline for online courses is not “reasonable accommodation” but rather “accessibility.”
Is there help available?
Corrine Haverinen, Assistive Technology Specialist, has primary responsibility to assist faculty in making online courses and web-based instructional materials accessible. Corrine can be reached by phone (527-4699) or by SRJC e-mail at firstname.lastname@example.org. She is located in the Doyle Library, 3rd floor, Room 4427 in the Center for Excellence in Teaching & Learning. See the Assistance page for help with Canvas and captioning videos.
How can I develop the skills I need to make my online course or instructional materials accessible?
Trainings on how to make online classes accessible will be offered by our Assistive Technology Specialist. Trainings can be found on the Staff Development Menu of Activities. Some trainings are available online on the Web Accessibility Compliance Web site. All online faculty members and faculty members who post materials on the web for students are strongly encouraged to take the training. Flex credit will be provided for all trainings. The DE Assistive Technology Specialist is available for consultations, and faculty are encouraged to contact them for assistance.
If I developed my online class in our learning management system, do I need to worry about accessibility issues?
For class Web sites built in the SRJC learning management system (currently Canvas), the system automatically generates compliant web pages. Some features will need to be turned on or added for accessibility compliance. Access the Canvas Accessibility Guide for explanations of the common issues. Files created with desktop applications (such as PowerPoint, Word, Dreamweaver, Excel, InDesign, Acrobat, etc.) and linked to are not necessarily compliant. Likewise, if links point to sites outside the learning management system, there is no guarantee those external sites are compliant.
What are the time lines for review?
All new online sections that are first scheduled for Fall 2010 and thereafter must meet the Accessibility Design Guidelines established by SRJC. When a new course section is developed for online delivery and ready to launch, it must undergo a physical review for accessibility. In order for this review to be meaningful, ideally the course must be substantially complete. However, realistically some instructors develop content as they go along. In this case, the course must be reviewed before launch, and reviewed again upon the completion of the semester.
All existing sections will be reviewed on a six-years cycle determined by the Dean of Learning Resources and Educational Technology. Generally speaking, courses that are identified for review in a given year must be made accessible by first proof of Fall schedule, which is generally in late February. However, if more time is needed, the faculty member should e-mail the Dean of Learning Resources with an explanation of why accessibility compliance could not be met by the deadline. If the faculty member is working in good faith toward accessibility compliance, an extension may be granted.
A faculty member who fails to respond to or participate in a required accessibility review for a particular course will not be scheduled to teach that course. The Dean of Learning Resources will work with Supervising Administrators to assure that the course in not scheduled. A faculty member can appeal the decision to the Vice-President of Academic Affairs.
What if my course is scheduled for review in a particular academic year, but I am not teaching the course that year or it is canceled?
If you are not teaching the course in the year it is scheduled for review, or if the course is canceled that year, e-mail the Dean of Learning Resources with the information that you do not expect to be teaching the course, and the review date will be moved to the following year. If you do not expect to teach the course again in the future, that will be noted on the list and no review is necessary. If circumstances change and you are scheduled to teach the course again, you will be expected to be reviewed and pass accessibility compliance before you teach the course.
What is the difference between the Distance Ed Advisory Committee (DEAC) review and accessibility review?
New courses being proposed for online delivery must go through a Distance Education Advisory Committee (DEAC) review and approval by the Curriculum Review Committee as suitable for online teaching. It is recommended that faculty check in with the Distance Education Assistive Technology Specialist for a consultation about accessibility requirements before starting to create online materials for new courses. This consultation is no longer a requirement in the DE proposal process, but can save the instructor time in knowing about accessibility compliance procedures from the start. Later, when the course has actually been developed, it must go through the accessibility review before launching.
How is accessibility checked?
The accessibility checker adopted by SRJC is WAVE (WAVE Firefox add-on or WAVE Chrome add-on). Faculty may utilize this tool themselves and/or attend a flex workshop to learn how to check their own online classes using WAVE. The Distance Education Assistive Technology Specialist will conduct the accessibility review using the WAVE Firefox add-on. However, not all accessibility issues can be adequately checked by WAVE. The Assistive Technology Specialist will use their expertise to evaluate all the issues included on a Web Accessibility checklist based on the Section 508 rules and WCAG 2.0 standards at the AA level.
The accessibility check is only about the logistical aspects of online course accessibility; similar to checking to be sure that physical classrooms are accessible. Course content will not be reviewed, evaluated, discussed, or shared among those handling the Accessibility Review. The Accessibility Review will not be used in any way in the faculty evaluation process.
What will be reviewed?
All class content created and/or controlled by the instructor will be reviewed for compliance, including content created within the CATE or Moodle systems by the instructor, files uploaded to the CATE/Moodle server by the instructor, and material created or controlled by the instructor but hosted on another server. In addition, class content maintained and hosted elsewhere will be reviewed for compliance, including class content provided by textbook publishers and other third-party Web sites. All class materials required or realistically necessary for completion of a class will be reviewed. Optional materials not hosted on an SRJC server will not be reviewed.
What is the accessibility review process?
Courses scheduled for accessibility review will be notified by the Distance Education department. Online faculty members should respond promptly to this notice, and set up a meeting time with the DE Assistive Technology Specialist to review the course together (see contact information provided above, and on the Assistance page). Faculty members who live at a distance may participate in the review by phone.
- The accessibility check can be done without removing password protection.
- Faculty whose courses have been identified for accessibility review in a given year should contact the Assistive Technology Specialist early in the fall semester to avoid a rush or an impossible deadline in February.
- Faculty teaching a particular course online for the first time will also have the responsibility to schedule an accessibility review as soon as the materials are completed, ideally before the start of the class. If the instructor will be developing content as the class is being taught, the course must be reviewed before the class starts, and reviewed again upon completion of the materials.
- Faculty members must provide all materials that are/will be accessed by the student online. If some materials, such as PowerPoint presentations, videos, Word docs, PDFs, HTML files, etc. are not accessible online at the time of the accessibility review, they should arrange to bring them on CD, DVD or flash drive.
- If the online course does not pass the accessibility review, the faculty member will be given a list of those elements that need to be fixed. The Assistive Technology Specialist will continue to provide direct assistance in helping the faculty member acquire the tools and skills required to make the site accessible.
What if a particular course cannot be made accessible to students with a particular disability because of the fundamental nature of the discipline or the materials?
If making an online course accessible would alter the fundamental nature of the course, an exemption may be possible for certain disabilities. For example, a student with severe hearing impairment might not be able to participate in Music Appreciation. The music course might be exempt from serving students with a severe hearing impairment, but not exempt from serving students with a visual impairment. Instructors who feel an exemption is warranted for a particular course should e-mail the Dean of Learning Resources. The Dean will consult with the Director of the Disabilities Resources Department, to decide if an exemption is reasonable. They may need access to the course to make a judgment.
What about the impact on faculty workload? What if I have an online class that is time-consuming to make accessible?
We recommend that complex or media-rich classes go through the review process sooner rather than later. If making a course compliant requires a lot of time, the Dean of Learning Resources can extend the deadline and allow extra time to bring the course into compliance. The workload can be spread over several years, if necessary. The Assistive Technology Specialist and student DE staff will provide help with some aspects of accessibility compliance, such as PDF accessibility.
What if a publisher’s Web site fails the accessibility review?
Many publisher’s Web sites are not fully compliant with the law, even though they should be. If a Web site has only a few minor issues, but the content is accessible to a student with disabilities, we will continue to use it. If the Web site has many issues or major problems, the Dean will send a letter to the publisher with a list of those issues. The instructor can continue to use the Web site as we work with the publisher on compliance.
What if I am using lecture materials or videos that need to be captioned?
Currently, a state-wide grant is covering the cost of captioning lectures, films, and videos. Contact the DE Assistive Technology Specialist, and about submitting materials for captioning. Media Services will oversee the captioning process. It would be a good idea to have those captioned sooner rather than later.
What about accessibility of face-to-face classes with Web enhancement?
Highest priority for assistance is given to online courses right now. However, all materials placed on the web for students must meet the Board Policy for accessibility and conform to the “SRJC Accessibility Design Principles for Online and Web-Based Class Materials.” Links to other Web sites that are required or realistically necessary for course completion must also be accessible, as discussed above (see the Canvas Accessibility page for the current policy on linking to third party sites). Instructors are responsible to assure that their instructional materials are accessible. Faculty members are encouraged to gain the knowledge and skills to make web materials accessible and to voluntarily make them accessible. Meanwhile, students must be provided with an alternative upon request.
What are the SRJC guidelines for accessibility of online courses and web-based instructional materials?
The guidelines for design are posted on the SRJC Web Accessibility Design Principles page of this Web site. These guidelines are based on the Section 508 rules. The shorter, summarized version of the guidelines can be found on the Web Accessibility Checklist page and has been updated to include WCAG 2.0 standards at the AA level. (Section 508 is undergoing a refresh that will reference the WCAG 2.0 standards). As questions arise, we can seek expert advice from the Chancellor’s office, and these guidelines may be clarified over time. Please be patient with this process. If you have a question about accessibility, contact the Assistive Technology Specialist.