Mary Hricko, Ph.D. Professor, University Libraries, Kent State University
As we begin a new year, one resolution that IT leaders and higher education administrators should consider involves implementing directives that advance Universal Design for Learning (UDL). UDL principles promote quality assurance, support different learning styles, and expand access to digital learning materials such as open education resources (OERs).
Although many industry IT leaders are aware of the importance of adopting UDL principles in their EIT Accessibility Policies, implementing and ensuring similar application has proven problematic in higher education where complaints regarding accessibility issues continue to be filed with the Office of Civil Rights (OCR). In a 2015 white paper report entitled, IT Accessibility Risk Statements and Evidence developed by EDUCAUSE’s IT Accessibility Constituent Group, a list of risk management issues involving higher education institutions were outlined along with evidence of legal cases to help higher IT administrators conduct a review of their own risk management processes.
While many of the OCR rulings relate to specific internal compliance issues such as failure to provide faculty accessibility training, there are three important risk management issues in which the education technology industry could provide leadership and support for higher education to improve implementation of UDL practices. These three key areas include: preparing accessibility statements, improving closed captioning, and increasing accessibility of open education resources.
Improving Accessibility Statements
When Section 508 passed its guidelines for accessibility, industry IT leaders had to ensure that their technology tools met the government’s requirements for compliance. As a result of this legislation, many industries prepared a Voluntary Product Accessibility Template (VPAT™) for their products. A VPAT is a document that explains how information and communication technology (ICT) products such as software, hardware, electronic content, and support documentation conform to the Revised 508 Standards for EIT accessibility.
Similar to a VPAT, an accessibility statement provides an overview of the accessibility features of a given resource and offers contact information for consumers who may have questions or concerns if they are unable to use the resource. Accessibility statements include the following details:
1. A list of accessibility features of the resource that has been added
2. Instructions that explain how to customize the resource
3. Information regarding the limitations of the resource
4. Contact information for questions or concerns
5. A summary of the resource’s accessibility policy
6. The date in which this information was last updated
While most individuals think that accessibility statements are included in the development of digital learning resources, numerous resources, especially in the OER arena, provide no documentation regarding accessibility. Since accessibility statements are required elements in the National Standards for Quality Online Courses, curating resources that meet such guidelines can prove challenging. The inclusion of accessibility statements for all technologies provides valuable information for learners who need special accommodations.
To address this issue, IT leaders can work with higher education institutions to develop better tools that generate accessibility statements for curated content. WCAG and the BC Accessibility Mary Hricko | 9|AUGUST 2021 Toolkit offer a good model for developing accessibility statements, but IT leaders involved with curation projects for digital repositories should ensure that all items being housed in such repositories include current accessibility statements. Dated accessibility statements are not useful to anyone.
“Through collaboration, IT leaders and higher education officials could expand open education by finding strategies to better prepare accessibility statements, improve the use of closed captioning, and increase OER accessibility”
Another major issue found in the IT Accessibility Risk Statement and Evidence report was related to numerous challenges regarding closed captioning. Failure to provide accurate video closed captioning was listed as one of the primary consumer complaints to the OCR. Captioning has become a major concern of higher education administrations because of the cost and time management of providing real-time services. In addition to instructional uses, captioning services are also required in other aspects of college life. The National Association for the Deaf (NAD) filed lawsuits against several academic institutions for failure to provide captioning of announcements and commentary made public at sporting events.
Since instructors rely on narrated presentations and videos in their courses, some institutions have paced captioning responsibilities on the instructors. Embedding captions in videos as derivative works can prove challenging in some cases where copyright permissions are not granted. Unless the video allows permission to modify, such as a creative commons license (CCBY), instructors have to secure an accessible copy of the video. Many individuals unable to secure the materials they need for their teaching have begun to create their own learning resources. This practice can prove problematic if these individuals do not know how to create an equivalent caption or transcript properly.
Institutions have created procurement policies that will not allow the purchase of resources that are inaccessible for modification. The IT industry can take a greater lead in working with higher education to develop more cost-effective strategies to create closed-captioned learning objects. More importantly, products with video and audio content should also provide closed captioning and transcripts from the beginning. Such development merits not only students with disabilities, but also second language learners, international students, and individuals who prefer listening to reading.
Increasing Accessibility of Open Education Resources
While many OERs are developed with UDL principles and open textbook repositories such as the OER Commons, Merlot, and the Open Textbook Network (OTN) are involved with curating resources that have been evaluated for their accessibility, there needs to be a consistent practice in place for the curation of all OERs. IT Leaders involved in any digital repository project should consider increasing the accessibility of the open education resources they include in their platforms.
All of the resources that are being curated should include an accessibility statement, and if the resource includes multimedia, then there needs to be closed captioning or transcripts for the resource. It is equally important that items being curated be CCBY licensed to ensure the greatest level of modification. While open education resources can offer several licenses, it is best to curate those resources that ensure the greatest level of flexibility for learning.
In 2013, MERLOT, Open Education Consortium, California State University, and the National Federation of the Blind worked together to create an OER toolkit that enables content creators to develop accessible materials. This project proved very helpful in developing accessible OERs, but much more needs to be done. IT leaders can further focus on the development of additional tools that make it easier for education technologists and educators to develop accessible content. More work needs to focus on developing accessible content for mathematics and second language learning. Having such tools can also help develop much needed ancillary materials to supplement OER textbooks. Ancillary material development will further increase the adoption of open access mater ials and support affordable learning for disadvantaged learners.
Access to education is a universal right. We bear the responsibility of engaging in collaborative projects that support this mission. Through collaboration, IT leaders and higher education officials could expand open education by finding strategies to prepare accessibility statements better, improve the use of closed captioning, and increase OER accessibility. Working together to resolves these risk management issues will advance open access to education and make a global impact on learning.