Building a Plan to Help Educators Through the OCR Resolution Process
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The OCR resolution process has a tendency to induce panic in educators nationwide. This presentation will give you the perspective you need to not only get through a resolution, but to build a scalable process for your unique needs.
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Building a Plan to Help Educators Through the OCR Resolution Process
- 1. Building a Plan to Help Educators Through the OCR Resolution Process 1
- 2. An OCR complaint has a tendency to cause panic in educators nationwide. The “New” American Horror Story 2
- 3. What is OCR? OCR is the US Department of Education’s Office of Civil Rights OCR’s mission is to ensure equal access to education and to promote educational excellence through vigorous enforcement of civil rights in our nation's schools. 3
- 4. A Brief History The Office for Civil Rights (OCR) enforces federal civil rights laws that prohibit discrimination in programs or activities that receive federal financial assistance from the Department of Education. Discrimination against persons with disabilities is prohibited by Section 504 and Title II of the ADA. Title II affects public entities whether or not they receive federal funding. 4
- 5. Who is affected by these complaints? We see complaints across all industries, but education has been one of the hardest hit areas for accessibility. •K-12 Districts •Charter Schools •Private Schools •State Education Departments •Education Cooperatives •Community Colleges •Colleges and Universities 5
- 6. • This is not a lawsuit • Section 504 and Title II of the ADA • How do I know if OCR is investigating me? • What kinds of pages are affected? • Communicating with OCR • Whose fault is this? Breaking Down an OCR Complaint 6
- 7. • Timely • Rely on your legal counsel • List of items for response • List of pages (4-12 is typical) • Current policies and procedures related to your website • Vendors used, and if they provided VPAT documents or other assurances • Contact info of person responsible for Web accessibility • Documents regarding efforts to make the site accessible • Any monitoring or reports used to evaluate website accessibility • Any complaints received • Any other documents you feel OCR needs for consideration in this complaint Responding to OCR 7
- 8. Resolution Agreement Remedies and Reporting • Policies and Procedures for New Online Content and Functionality (Plan for New Content) • Undue Burden • Designate Auditor • Audit of Content and Functionality • Proposed Corrective Action Plan • Policy/Accessibility Notice • Training • Provide accessibility training to appropriate staff quarterly or annually 8
- 9. 2. Undue Burden Resolution Agreement 9
- 10. 3. Audit of Existing Content Auditor with bona fides (qualifications) i.e. the person who will review the internal audit and assist the school with the testing and resolution process. Internal Auditor? External Auditor? Resolution Agreement 10
- 11. 4. Proposed Corrective Action Plan • Support • Funding • Strategic Planning • Communications • Education • Partnerships • Monitoring Resolution Agreement 11
- 12. 5. Adoption of CAP Resolution Agreement 12
- 13. 6. Proposed Notice to Persons with Disabilities Resolution Agreement 13
- 15. 8. Ongoing Monitoring by OCR Resolution Agreement 15
- 16. • Sitewide • Automated Testing • Manual Testing • Sampling of pages for manual testing • Template pages • Popular pages • Pages in complaint • Functional elements • User paths/journeys Auditing/Testing Begins 16
- 17. • Site templates • Representational content pages • Dynamic content pages • Dialog modals and alerts • Key entry and exit pages (including account login and recovery pages) • Help and assistance pages • Interactive forms Automated 17
- 18. • Page zoom • Form elements and form validation • Visible focus • Multimedia and media control • Dynamic elements • Modals and dialog boxes • Modal receives focus • No keyboard trap • Close modal Manual 18
- 19. • Headings • Links • Forms • Images • Multiple browsers, platforms • PC/Mac • Chrome/FF/IE/Edge Assistive Technology 19
- 20. • Combine automated, manual, and AT test results into a comprehensive report for OCR Audit Results 20
- 21. Corrective Action Plan • Staff Responsibilities • Funding • Communication • Training • Vendor Relationships • Ongoing Plans 21
- 22. • Fix or start over? • Addressing old site issues • Resources • Vendors • Documents • Multimedia • Third Party Pages/Plug ins Remediation 22
- 23. • OCR requirement • Accessibility awareness • Basic Web skills • Documents • Assistive tech • User task-based testing • PwD testers Training 23
- 24. Next Steps So your received a complaint from the OCR. Now what? • Work with your legal counsel and draft a response to OCR 1.Submit an auditor and a Plan for New Content • Audit approved 2.Audit/testing begins 3.Auditor creates audit report 4.Auditor assists with Corrective Action Plan 5.Submit report and CAP • Remediation begins • Training • Ongoing monitoring • Sign-off by OCR 24
- 25. We are changing a culture • Buy-in • Awareness education • Organizational policies • Budgetary considerations 25
- 26. • Identify (realistic) goals • Timelines (marathon not a sprint) • Action plans • Define milestones • Budgetary considerations • Identify existing resources • Address legal/regulatory issues Start your accessibility program 26
- 27. • How do we portray the level of importance? • Security compliance training? • Sexual harassment training? • Awareness • Technical training • Role-based training •Faculty •Staff •Documents Staff Training 27
- 28. • Ownership of digital properties • Role-based team members • Inventory •Web pages •Documents •Multimedia Identify Existing Resources 28
- 29. • Management • Human Resources • Marketing • IT Office • Compliance/Legal • Purchasing • Other Community Stakeholders • External Agencies Buy-in from Stakeholders 29
- 30. Community Stakeholders • Department Lead • Faculty/Staff • Blended classroom environments • Use of multimedia • Documents • Disability Services Office • Students with disabilities that go unreported • Development/IT Teams 30
- 31. Concrete Policy and Plan • Communications/Transparency • Visible Policy and Contact Info • Implementation plan • Remediation plan 31
- 32. Sufficient Support • Divide work based on roles • Education program 32
- 33. Ongoing evaluation • Monitoring tools and processes • Continuing education 33
- 34. • Resources, training, and technologies can affect your approach to an OCR resolution • Creating a scalable process • Accessibility is a cultural issue • Takeaways: • Firmer understanding of how to approach an OCR resolution • Tools needed to build a plan to achieve ongoing accessibility compliance Remember 34
- 35. Digital Accessibility is a Process Not a Project The Project Management Institute defines a project as a “temporary endeavor undertaken to create a project, service, or result.” A process can be defined as a series of actions or steps taken in order to achieve a particular end. 35
- 36. Staff Responsibilities • Who is directly involved with our website and what are their responsibilities? • Developers • Content creators • Decision makers • Who is ultimately responsible for making sure compliance is achieved? • How do we track progress? 36
- 37. Funding Is this initiative being funded at an institutional level or is a specific department responsible? 37
- 38. Communication How do we communicate to employees that this is an organization-wide issue and everyone plays a part? How do we communicate this externally? A website policy? An accessibility section on the website? 38
- 39. Vendor Relationships Do our third-party vendors support accessible content creation? Are their products themselves accessible if our employees require accessible technology? Do we write accessibility (requirements/expectations/etc.?) into our contracts, RFPs, etc.? 39
- 40. • Complaint • Resolution Agreement • Remediation • Training Be Sure the Process for is Scalable 40
- 41. …and finally • Accessibility has to be on your radar. • There is no silver bullet when it comes to accessibility. • Understanding accessibility and accessibility issues has to be an ongoing conversation. • Accessibility is an issue that touches everyone in an organization. 41
- 43. 43 Icons downloaded from flaticon.com licensed by Creative Commons (CC 3.0 BY) Authors: • Freepik • Smartline • Dot-on-Paper • Vectors-Market • Marta-Copola • Madebyoliver • Hadrien • Madebyoliver
Editor's Notes
- This presentation will give you the perspective you need to not only get through a resolution, but to build a scalable process for your unique needs.
- This presentation will give you the perspective you need to not only get through a resolution, but to build a scalable process for your unique needs.
- This presentation will give you the perspective you need to not only get through a resolution, but to build a scalable process for your unique needs.
- This presentation will give you the perspective you need to not only get through a resolution, but to build a scalable process for your unique needs.
- i) Policies and Procedures for New Online Content and Functionality (Plan for New Content) (1) Submit for approval (2) Adopt and implement after receiving approval ii) Undue Burden iii) Designate Auditor (1) Submit for Bona Fides for Approval (2) Proof that Auditor is retained after receiving Approval iv) Audit of Content and Functionality (1) Submit Audit v) Proposed Corrective Action Plan (1) Submit Corrective Action Plan (2 )Adopt and implement CAP after receiving approval vi) Policy/Accessibility Notice (1) Submit for Approval (2) Post approved notice/policy vii) Training viii) Provide accessibility training to appropriate staff quarterly or annually
- Staff Responsibilities Who is directly involved with our website and what are their responsibilities? Developers Content creators Decision makers Who is ultimately responsible for making sure compliance is achieved? How do we track progress?
- Keeping accessibility within the testing phase traps it as a project problem. The Project Management Institute defines a project as a “temporary endeavor undertaken to create a project, service, or result.” Since projects are unique by their definition, it stands to reason that the same flaws and risks are bound to be repeated because testing for accessibility is the only place flaws and risks are going to be identified. When it remains at the project level, nothing changes to prevent it from becoming a problem in the first place. In my opinion, the question Designers and Developers should be asking is, “What’s the best method to employ so my users will react to it the way I expect them to?” To be able to arrive at that answer, accessibility needs to be taken out of the context of making it work for a specific implementation and more about doing things according to the theories of development best practices. Developers and Designers should begin to understand that accessibility is not a project problem, but a process problem. A process can be defined as a series of actions or steps taken in order to achieve a particular end. When considered as a process, the conversation becomes addressing the behavior that’s employed to perform an activity.