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Accessibility Compliance: One State, Two Approaches


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Accessibility compliance is a growing concern for academic institutions as it pertains to instructional materials on websites, course management systems, and in course documents. This extends to materials provided by academic libraries such as electronic resources. This presentation will discuss the approaches that both systems governing Tennessee public colleges and universities are using to ensure that vendors are compliant with standards as described in WCAG 2.0, EPUB 3, and Section 508 of the Rehabilitation Act of 1973.

The session will be divided into three parts as follows:

Introduction to the difference between accessibility and accommodation. Discussion of the types of disabilities of which librarians should be aware when acquiring and assessing different electronic resources. Brief mention of the laws and standards related to accessibility compliance.

An overview of the University of Tennessee System’s approach to encouraging accessibility compliance by incorporating detailed conformance language into licenses with the vendors and publishers of electronic and information technology.

A discussion of the Tennessee Board of Regents system’s approach to encouraging accessibility compliance by conducting an accessibility audit of resources held in common among the system’s libraries and through a collaborative process of compliance document collection from vendors/publishers and sharing in an AIMT (Accessible Instructional Materials and Technology) database. An introduction to the different types of documents and their content: Accessibility Statement, Voluntary Product Accessibility Template (VPAT), WCAG 2.0 (Web Content Accessibility Guidelines) Checklist, EPUB 3 Accessibility Checklist, and a Conformance and Remediation Form.
Stephanie J. Adams
Electronic Resources Librarian, Tennessee Tech University
Ms. Adams is the Electronic Resources Librarian at Tennessee Tech University where she is responsible for the acquisition and set-up of all electronic resources at the Volpe Library.
Corey S. Halaychik
The University of Tennessee, Knoxville
Licensing guy, negotiator of master agreements at the University of Tennessee Libraries, and co-chair of The Collective, I work to make libraries more efficient, saving time and money for institutions and the people they serve.
Jennifer Mezick
Pellissippi State Community College
Acquisitions and Collection Development Librarian at Pellissippi State Community College in Knoxville, TN. In addition to these roles, I manage the libraries' electronic resources and website, and provide instruction and research support to students and faculty.

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Accessibility Compliance: One State, Two Approaches

  1. 1. Accessibility Compliance: One State, Two Approaches Stephanie J. Adams Tennessee Tech University Jennifer Mezick Pellissippi State Community College Corey Halaychik The University of Tennessee, Knoxville
  2. 2. Overview  Accessibility defined  Types of disabilities and accessible design features  Laws and lawsuits  Task Force formation  Tennessee Board of Regents (TBR) Libraries Accessibility Task Force activities and plans  Accessibility documentation standards  University of Tennessee System process, results, and plans
  3. 3. Accessible vs. Accommodation “Accessible means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally and independently as a person without a disability.” -U.S. Department of Education, Office for Civil Rights (OCR resolutions with South Carolina Technical College System, University of Cincinnati, and Youngstown State) “Accommodations are reasonable academic adjustments or auxiliary aids that provide equal access to programs and services on an individual basis.” -Tennessee Tech University Accessibility Initiative
  4. 4. Examples of Accessible Design Features Types of Disabilities  Visual  Auditory  Neurological  Motor/Mobility  Cognitive  Speech Accessible Features  Alternate text for images  Captioning for audio/video  Absence of flickering images  Full keyboard support for navigation  Simple navigation tools and page layouts, conceptual explanations  Help or tech support via a variety of methods (not just telephone) WebAIM: Introduction to Web Accessibility: W3C Web Accessibility Initiative: Diversity of Web Users:
  5. 5. Laws Related to Accessibility in Higher Education  Section 504 of the Rehabilitation Act of 1973  Section 508 of the Rehabilitation Act of 1973 as amended (in 1998)  Title II of the American with Disabilities Act of 1990  Title III of the American with Disabilities Act of 1990  In Tennessee: Senate Bill No. 1692 (signed into law on April 16, 2014) K. Ostergard’s “Accessibility from Scratch” – Table 1 DOI: 10.1080/0361526X.2015.1069777 Implementing Accessibility at UTM:
  6. 6. Complaints in Libraries and Higher Education  Public Libraries: NOOK eReaders  Higher Education:  Websites  Course management/learning management systems and online learning platforms  Kindle DX eReaders  Videos without captioning  Course registration systems  Textbooks and other course materials  Technology (including classroom clickers)  Gmail and Google Apps  Library systems and databases
  7. 7. Legal Action in Higher Education: Library Materials  Penn State University (Resolution Agreement) National Federation of the Blind (NFB) filed a complaint regarding inaccessible websites.  University of California at Berkeley (Lawsuit settled in 2013) Disability Rights Advocates (DRA) filed lawsuit citing inaccessibility of library materials for students with print-related disabilities  University of Montana-Missoula (Resolution Agreement) Investigated by the Office of Civil Rights (OCR) in the U.S. Department of Education for complaints including inaccessible library database materials. Higher Ed Accessibility Lawsuits, Complaints, and Settlements
  8. 8. Tennessee Board of Regents System: Who We Are  One of two systems of Tennessee public higher education  Largest system of higher education in Tennessee  13 Community Colleges  27 Colleges of Applied Technology  TN eCampus (46 partner institutions, 500+ certificates and degrees)  Serves 100,000+ students  6 Universities  Serve 88,000 students (75,000 undergraduate & 13,000 graduate and professional students)
  9. 9. Tennessee Board of Regents Libraries Accessibility Task Force  Tennessee Higher Education Commission (THEC) Accessibility Task Force charged TBR and UT with creating policies for accessible IMT (information materials and technologies)  TBR Accessibility Task Force formed in Spring 2015  TBR Libraries Accessibility Task Force formed in Spring 2016  Members: interested library staff from any of the TBR and UT schools  Purpose: deliver a plan for an accessibility audit of library resources
  10. 10. TBR Libraries Accessibility Task Force: Initial Goals  Initial audit of library instructional materials and technology (IMT)  Challenges • Selecting tools/developing audit rubric (WAVE, WebAIM checklist) • Interpreting results • Recruiting end-user testers  Develop a collaborative process for procurement of AIMT (Accessible IMT)  Master list of eResources (divide and conquer approach)  Vendor form letter  Accessibility document roundup  AIMT database contributions
  11. 11. Accessible Product Documentation: Standard Forms  Accessibility Statement: statement of commitment to ensuring equal access to all users  VPAT: Voluntary Product Accessibility Template  WCAG 2.0 Checklist  EPUB 3 Accessibility Checklist
  12. 12. Standard Compliance Forms: Accessibility Statement ProQuest Academic Accessibility Statement
  13. 13. VPAT: Voluntary Product Accessibility Template  Developed by ITI (Information Technology Industry Council) and the GSA (U.S. General Services Administration)  Provides information on how EIT conforms to the Section 508 Accessibility Standards  Form is to be completed by vendors or publishers  Template available at:  LUA (Libraries for Universal Access) maintains a VPAT Repository at:
  14. 14. Standard Compliance Forms: VPAT
  15. 15. Web Content Accessibility Guidelines WCAG 2.0 – Levels A through AAA Key Principles  Perceivable: Information must be presented in a manner that users can perceive (Example: captions for audio)  Operable: User must be able to navigate and operate the interface (Example: Keyboard shortcuts in place of using the mouse)  Understandable: User must be able to understand how to use the interface (Example: Consistent navigation on each page)  Robust: Content must be able to be interpreted by assistive technology (Example: Markup language contains start and end tags for screen readers) WC3: Web Accessibility Initiative
  16. 16. Standard Compliance Forms: WCAG 2.0 Checklist Blank checklist used by TBR available at:
  17. 17. Standard Compliance Forms: EPUB 3 Checklist EPUB 3 Accessibility Guidelines: Accessibility QA Checklist
  18. 18. Accessible Product Documentation: Additional TBR Forms  Conformance and Remediation Form: identifies accessibility issues/gaps and indicates a timeline for conformance  Alternate Access Plan: describes the process for accessing AIMT when it does not conform to accepted accessibility guidelines (for example: WCAG 2.0 Level AA)
  19. 19. Additional TBR Forms: Conformance and Remediation Form Blank forms available at:
  20. 20. Additional TBR Forms: Alternate Access Plan Blank forms available at:
  21. 21. Additional TBR Forms: Alternate Access Plan
  22. 22. Task Force Activities: Document Collection Created by the TBR Libraries Accessibility Task Force. Vendor Form Letter
  23. 23. Task Force Activities: AIMT database
  24. 24. Task Force Activities: Audit Checklist created by Brittany Richardson and Sandra Wilford at Chattanooga State Community College and Livy Simpson at Volunteer State Community College.
  25. 25. TBR Task Force: Moving Forward  Finalize audit checklist  Audit a sampling of databases  Continue to gather and share documents  Work with TBR to improve AIMT database format & features  Develop and share Alternate Access Plans  Follow-up on Conformance and Remediation Form timelines
  26. 26. TBR Licensing Language Service and Software Accessibility Standards. The Contractor warrants and represents that the service and software, including any updates, provided to the Institution will meet the accessibility standards set forth in WCAG 2.0 AA (also known as ISO standard, ISO/IEC 40500:2012) and will be compliant with Section 508 of the Americans with Disabilities Act (ADA) with exceptions, if applicable. Copies of Contractor’s Voluntary Product Accessibility Templates (“VPATs”) for the various products and other accessibility information are available at URL.”
  27. 27. University of Tennessee: Who We Are  Public university system  4 Campuses (Chattanooga, Knoxville, Martin, & Memphis)  3 Institutes (Agriculture-Veterinary, Public Service, & Space)  1 Medical library (UT Medical Center)  Serves 49,000 students (38,000 undergraduate & 11,000 graduate)
  28. 28. University of Tennessee: Status UT Schools TBR Schools
  29. 29. University of Tennessee: Process  Libraries have been largely absent  No combined effort  System Office of General Counsel  System Procurement Office  Campus task forces  Libraries (internal & external)  Limited proactivity  No documentation, auditing, or testing
  30. 30. University of Tennessee: Language
  31. 31. University of Tennessee: Results  Lengthy drafting process  No standard language at outset  Vendors apprehensive  Walked away from a couple of purchases  Newer agreements contain some form of the language  Older agreements still need to be amended  No proof of compliance collected
  32. 32. University of Tennessee: Moving Forward  System  Supplied language but otherwise not involved  Campuses  Have task forces looking at all accessibility issues  Libraries  Electronic Resources Group is identifying ways we can work together to: • Audit for compliance • Compile documentation • Modify language to include clauses for remedies, protections, and reporting
  33. 33. Additional Resources Recommendations of the [Tennessee] Higher Education Accessibility Task Force 0Force%20Recs-Final.pdf TBR Libraries: Accessibility Audit Plan (as of April 2016) RLibraries_2016apr26.docx Tennessee Board of Regents: Accessibility Initiative
  34. 34. Questions? Tennessee Board of Regents System Stephanie J. Adams Tennessee Tech University Jennifer Mezick Pellissippi State Community College University of Tennessee System Corey Halaychik The University of Tennessee, Knoxville