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When the DOJ/OCR Makes a Visit: Lessons Learned in Resolving Complaints About Inaccessible IT

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Over the last few years, many institutions of higher education have faced legal action for inaccessible IT. If an ADA or Section 504 accessibility complaint is filed at your school, the Department of Justice (DOJ) and the U.S. Department of Education Office for Civil Rights (OCR) share the responsibility for enforcing the law. They also have the authority to conduct a compliance audit in lieu of a complaint.

In this webinar, accessibility leaders at three different universities will discuss what to expect in a DOJ or OCR review, as well as the lessons they've learned at their institutions in resolving complaints about inaccessible IT. Learning from schools that have successfully resolved DOJ/OCR complaints, this webinar will provide valuable insight into how campus communities can work to ensure the accessibility of IT.

This presentation will cover:

Schools that have faced legal action for inaccessible IT
Approaching accessibility and universal design at the university level
A timeline of the OCR complaint against University of Montana
University of Montana's resolution agreement
University of Montana's current approach to accessibility
A timeline of the DOJ inquiry at University of Colorado Boulder
UC Boulder's response and strategy for accessibility
What UC Boulder learned from their experience
Key takeaways from resolving DOJ and OCR complaints

Published in: Technology
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When the DOJ/OCR Makes a Visit: Lessons Learned in Resolving Complaints About Inaccessible IT

  1. 1. When the DOJ/OCR Makes a Visit: Lessons Learned in Resolving Complaints About Inaccessible IT www.3playmedia.com twitter: @3playmedia #a11y  Type questions in the window during the presentation  This presentation is being recorded and will be available for replay  To view live captions, please follow the link in the chat window Sheryl Burgstahler Director, Accessible Technology Services University of Washington Dan Jones Chief Digital Accessibility Officer University of Colorado Boulder Janet Sedgley Manager, Accessible Technology Services University of Montana Lily Bond (Moderator) 3Play Media lily@3playmedia.com
  2. 2. OLC Workshops of Interest to You • Special discounts available for OLC Members! April 13 – 15, 2016 - Designing with Accessibility in Mind – 3 Day Workshop http://onlinelearningconsortium.org/learn/workshops
  3. 3. When the DoJ/OCR Makes a Visit: Campus Leaders Discuss Lessons Learned in Resolving Complaints About Inaccessible IT > Sheryl Burgstahler, University of Washington > Dan Jones, University of Colorado Boulder > Janet Sedgley, University of Montana
  4. 4. What do they have in common? University of Cincinnati • Youngstown State University • University of Colorado-Boulder • University of Montana-Missoula • UC Berkeley • South Carolina Technical College System • Louisiana Tech University • MIT • Maricopa Community College District • Florida State University • CSU Fullerton • California Community Colleges • Ohio State University: University of Kentucky • Harvard University www.uw.edu/accessibility/requirements/
  5. 5. What is the legal basis? > Section 504 of the Rehabilitation Act > The Americans with Disabilities Act & its 2008 Amendments > State & local laws But what if laws don’t specifically mention IT?
  6. 6. Consider ability on a continuum see hear walk read print write with pen or pencil communicate verbally tune out distraction learn manage physical/mental health
  7. 7. Definition of “accessible” “Accessible” means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, & enjoy the same services as a person without a disability in an equally effective & equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally & independently as a person without a disability.
  8. 8. Approaches to access: > Accommodations > Universal design Both are important!
  9. 9. Universal design = “the design of products & environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.” The Center for Universal Design www.design.ncsu.edu/cud
  10. 10. Uncaptioned video Captioned video Interpreter for deaf student UD on a continuum
  11. 11. Key aspects of UW approach (without civil rights complaint) > Promote accessibility within context of universal design, civil rights, & inclusive campus culture > With UW-IT’s Accessible Technology Services as lead, resource, catalyst, & community-builder: – support efforts of Disability Resources for Students – develop & evolve “ideal state” & gap analyses – create list of IT products developed, procured & used, prioritize, determine strategy, assign staff – lead a top-level IT accessibility task force with key stakeholders, clear direction, regular reports
  12. 12. Key aspects of UW approach > With UW-IT’s Accessible Technology Services as lead, resource, catalyst, & community-builder, cont.: – develop partnerships & empower stakeholders within their roles in a distributed computing environment – provide guidance on an IT accessibility website – develop IT accessibility guidelines & standards – offer training & consultation, support user group – host captioning parties, meetings with Hadi, & other events – proactively test websites, PDFs & offer remediation
  13. 13. University of Montana timeline (with civil rights complaint) > An OCR complaint was filed against UM in the spring of 2012. > UM formed the EITA Task Force to help draft a UM policy & coordinate necessary support activities. > March 7, 2014: UM signed a resolution agreement with the Department of Education Office for Civil Rights. > UM provided 15 specific reports to the US Department of Education, related to areas such as web accessibility, classroom IT, & grievance processes. > March 2016: UM provided a full report documenting how UM has met required remediation action in the agreement that have not already been met.
  14. 14. UM resolution agreement (with US Department of Education Office for Civil Rights, March 2014) > Include accessibility requirements in all IT procurement > Survey current & former students about their experiences with barriers due to inaccessible IT at UM > Perform an accessibility audit of all IT on campus > Create a remediation plan based on results of the audit > Ensure document & web accessibility by the end of the year
  15. 15. Key aspects of UM approach > Teamwork with existing partnerships > Active partnership with LMS vendor > Top down / bottom up approaches > Consistent message linked to accessibility site > Building relationships > Building on existing processes > Formalizing involvement > Support from key leaders
  16. 16. University of Colorado Boulder response timeline (with US Department of Education Office for Civil Rights) > Initial accessibility study in 2013 > DoJ inquiry in Spring 2014 > Response & project formed in May 2014 (3-5 year project) OIT, Disability Services (part of ODECE – Office of Diversity, Equity, & Community Engagement), Legal, Procurement, many others > Investigation Closed May 18, 2015
  17. 17. UC Boulder response > Scope of work defined, resources identified, & teams formed (May 2014) > Project focal areas (June 2014) • Policy and exceptions process • Application and technical services remediation • Accessibility support services • Communication & documentation
  18. 18. UC Boulder lessons learned > Leadership commitment > Transparency with DoJ & community > Active engagement with community members who have a disability > Leveraging third parties for consultation & audits > Continuing engagement with community > Ensuring wide publication of accessibility issue reporting process
  19. 19. Overall lessons learned > Get commitment of leadership & key organizations, develop organizational structure with stakeholders > Identify key IT developed, procured, & used (websites, PDFs, videos, LMSs, ATMs, software) & develop – priorities – corrective action strategies & assignments – regular reports > Create & disseminate policies/guidelines/standards > Provide resources, training, promotional activities > Develop procurement policies & procedures > Develop & publicize grievance procedure
  20. 20. Who should be involved? > President, academic affairs, provost, deans, dept chairs > Academic senate, college council, council of chairs… > Student affairs > Students > Central campus IT unit > Outreach units > Libraries > Online learning programs > ADA compliance officer > Procurement It’s not just disability support services!
  21. 21. Questions > What partnerships on & off campus can you develop to support the IT accessibility goal? > How can we get support from administrators? > What are the best sources for providing guidance to your campus on concrete steps toward more accessible IT?
  22. 22. Q&A Upcoming Webinars:  Feb 25: 10 Tips for Implementing Accessible Online Media  Mar 10: Quick Start to Captioning  Mar 17: Quick Start to Video Search  Mar 31: The Legal Year in Review: Digital Access Cases You can register for our free webinars at: www.3playmedia.com/webinars/ Panelist Contact Info Sheryl Burgstahler University of Washington sherylb@uw.edu Dan Jones University of Colorado Boulder Dan.jones@colorado.edu Janet Sedgley University of Montana sedgleyj@mso.umt.edu Lily Bond 3Play Media www.3playmedia.com lily@3playmedia.com Please type your questions into the window in your control panel. A recording of this webinar will be available for replay.

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