The document discusses lessons learned from various universities regarding the resolution of complaints related to inaccessible IT, emphasizing strategies like universal design and effective communication. Key legal frameworks include the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. Recommendations involve leadership commitment, stakeholder engagement, and the establishment of clear policies and procedures for IT accessibility.

1. When the DOJ/OCR Makes a Visit: Lessons Learned
in Resolving Complaints About Inaccessible IT
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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. 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. 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. 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. 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. 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. 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. Approaches
to access:
> Accommodations
> Universal design
Both are important!

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. Uncaptioned
video
Captioned
video
Interpreter
for deaf
student
UD on a continuum

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. 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

14. 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.

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

21. 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!

22. 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?

23. 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:
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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
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