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CIO, EASI (Equal Access to Software and Information)
PO Box 818
Lake Forest CA 92609
Phone: (715) 233-3187
Joseph J. Lazzaro
Project Director: Adaptive Technology Program
Massachusetts Commission for the Blind
88 Kingston Street
Boston, MA 02111
Steve Noble, M.P.A., Policy Analyst
Kentucky Assistive Technology Service Network
8412 Westport Road
Louisville, KY 40242
Phone: (502) 327-0022
The National Center for Accessible E-learning, an EASI-sponsored coalition, serves as a clearing house for state-of-the-art information about e-learning legislation, policy and best practice: http://easi-elearn.org
After years of neglecting providing access to e-learning systems, schools, universities, businesses and grant-providing institutions have recently begun redesigning existing courseware systems to include access for students and faculty with disabilities. The software applications frequently used in online learning systems changes so frequently and rapidly that keeping up with it is a chore. Complicating this constant change now is the need to also keep informed on these systems' enhancements to provide necessary accessibility for users with disabilities. It is encouraging that so many ventures are taking place at once, but only those concerned with accessibility can be up-to-date on the ever-changing accessibility of various systems.
The National Center for Accessible E-learning is a web site (easi-elearn.org) that pulls together in one location an array of research projects, vendor software enhancements, policies and legislation and the experiences of content providers. The task is more than one organization can master and NCAE seeks active partners in this task. EASI continues to solicit sponsors and supporters in a coalition to be a rich resource for schools, universities and businesses eager to include accessibility in their online education courses.
Before describing the scope of the material available on the National Center for Accessible E-learning, (NCAE), web site, the presentation will focus on policies and legislation that underpins the drive for accessibility of these distance education technologies.
Policies and Legislation
Although many educational institutions may take on the issue of access to distance education technologies simply because they feel it is the right thing to do, many may be more compelled by the fact that significant legal issues are at work which demand that institutions consider access issues in all educational offerings. However, it is important for organizations to keep in mind that accessible e-learning technologies have the potential of removing many of the accessibility barriers to information access commonly found in standard classroom settings.
Information typically provided on chalkboards, overheads, and print handouts which may be inaccessible to students who are blind, visually-impaired or have learning disabilities can be made readily accessible if properly rendered in e-learning technology. Oral presentations which may be inaccessible to students with hearing impairments or difficult to process for students with Attention Deficit Disorder, can be produced for distance learning presentation with built-in access techniques such as captioning and display reinforcement abilities. Further, e-learning courseware can allow realistic computer simulations of laboratory experiments for students who cannot manipulate items in the physical world.
However, these same technologies also have the potential for making distance learning an inaccessible environment for people with disabilities. All too often, this has been the reality for people who cannot see the computer screen or for other reasons cannot effectively interact with a Graphical User Interface. Furthermore, many e-learning technologies will lock out the use of assistive technology access if not properly designed with access in mind at the beginning of the development process.
When students with disabilities are "locked out" of these educational offerings, however, institutions may be inadvertently breaking the law. For instance, Section 504 of the Rehabilitation Act prohibits educational institutions that are recipients of federal funds from discrimination on the basis of disability [29 U.S.C. 794]. Federal regulations enforcing this law indicate that recipient organizations cannot deny individuals with disabilities the "opportunity to participate in or benefit from" any aid, benefit, or service [34C.F.R.104.4 (b) (i)]. This same protection is similarly afforded against discrimination by any state or local government entity under Title II of the ADA [28C.F.R.35.130]. It is clear that the right of students with disabilities to participate in all class offerings of an educational institution is a fundamental tenet of law.
Federal regulations further indicate the extent to which participation by individuals with disabilities is to be guaranteed. In particular, Section 504 regulation 34C.F.R.104.4 states that an educational institution cannot provide students with disabilities an opportunity to participate in an aid, benefit, or service that is: (a) not equal to that afforded others; (b) not as effective as that provided to others, or; (c) different or separate than those provided to others unless required to provide one that is effective. To extend these concepts to e-learning situations, it follows that courses offered online or that include web-based components must allow an equal, effective, and inclusive opportunity for participation to students with disabilities. The institution has a clear responsibility to ensure that students with disabilities have an equal, effective, and inclusive opportunity to participate in any e-learning class or course component offered to others. All e-learning courseware and class offerings should be developed in such a way that students with disabilities using assistive technology will have equal, effective, and inclusive access.
In addition to the obligations applicable under the ADA and Section 504, many institutions may need to follow specific access standards under Section 508 of the Rehabilitation Act. Although Section 508 deals with obligations of the federal government, states my ultimately have to comply with these standards as well. In fact, many states have adopted Section 508 access standards as state policy, either by incorporating Section 508 within state law, or by issuing administrative policies at the state level.
Some contend that the costs involved in providing access to e-learning instruction is too expensive, and therefore not required by law due to it causing an undue burden. All too often this assumption is unfounded and is based upon conjecture rather than reasonable investigation. What is very clear, however, is that the costs of providing access are always less when incorporated at the beginning of the design stage. Furthermore, the ability to claim undue burden in cases of making poorly designed courseware accessible may be substantially restricted. In a settlement letter issued by the U.S. Department of Education, Office of Civil Rights, it was indicated that when an educational institution selects software programs which are inaccessible to students with disabilities, "the subsequent substantial expense of providing access is not generally regarded as an undue burden when such costs could have been significantly reduced by considering the issue of accessibility at the time of the initial selection" [U.S. Department of Education. Office of Civil Rights. Settlement Letter: Docket Number 09-97-2002]. It is quite evident that designing universal access into all e-learning components from the beginning is the most effective strategy for cost containment.
Components of accessible e-learning
The issues surrounding making e-learning systems accessible to users with disabilities fall into two major parts. Both the courseware and the actual course content itself need to be accessible. The courseware or the learning management system can be compared to the physical buildings on a campus. Before the student can even access the course, he or she must navigate the infrastructure whether that is a physical building to reach a classroom or software to reach the virtual classroom. Most universities do not create their own courseware system. Those that do must become very familiar with the Web Accessibility Initiative's web guidelines and the Access Board's Section 508 web standards. Purchasing a system rather than creating one in-house does not, however, relieve the university from the obligation to provide a system that is accessible to its students. All legislation that covers providing accessible education focuses on the school. No legislation requires the commercial courseware vendor to provide an accessible product. Even when purchasing a commercial product, the university will need to understand enough about the WAI guidelines and Section 508 standards to evaluate the vendor's claims.
Accessible courseware is one of the main navigation links on the Center's home page. The courseware page has links to the accessibility information posted on the sites for Blackboard, E-college and WebCT, the three most popular courseware systems. All of them are building help for content providers into their systems to facilitate the work of faculty, instructional designers and other content providers. Presently, the web accessibility checkers do not function to validate material located inside a courseware product. This means that content providers, themselves, are responsible for the accessibility of the material they post inside the courseware system.
Content accessibility is another major link from the NCAE home page. The school or university needs to develop a policy for content accessibility and to develop help for those providing that content. This is a daunting task. While some faculty or instructional designers are highly technical and have considerable computer know-how, others focus on their course content and do not want to become enmeshed in technical web issues. Where an institution has adequate support staff, someone can be designated to see that everything posted to e-learning courses are made accessible. Most institutions, however, are limited in the technical support they can provide to online faculty.
Most online faculty who do not want to become web designers limit their online postings to materials produced with a few common computer applications. This means that there is no need to overwhelm them with know-how about making complex, advanced items accessible. They can be provided with a short list of accessibility tools. Obviously, they need to know how to provide text labels for graphics. PowerPoint is a common presentation application, and faculty need to understand its accessibility problems and solutions. Posting content in PDF is also common, and it poses difficulties for users with screen readers. Faculty need to know either how to make that accessible or know how to post the content in an HTML format instead.
Some disciplines can make excellent use of animations to provide three dimensional simulations of experiments or real world events. While Flash is being designed to provide a high level of accessibility, some kinds of computer content cannot be fully accessible to a user who is blind. Links to a skillfully-written text description can go a long way and may be adequate for educational needs, but it can never really provide equal access.
Accessible multimedia is another topic that is important enough to merit a home page link on the Center. The National Center for Accessible Media at WGBH is one of the major resources for this page. SMIL, (synchronized multimedia integration language), is a specialized language that facilitates simultaneous streaming of video, audio and text captions. The captioning is essential to provide access to videos for students who are deaf. Including a track with audio descriptions of the action in the video enables students who are blind to access the video content that may be needed to understand important concepts in a course.
Another major area of the web site points to training opportunities and courses related to making online learning accessible to students with disabilities. EASI, of course, has provided material on this topic for years. EASI's courses now can be taken to earn a Certificate in Accessible Information Technology. EASI's online courses are:
These courses are primarily designed for school, university, library and business administrators and staff to facilitate their creating an institution-wide accessible information technology system for their students, employees and for the public. EASI is a non-profit organization, which, since 1988, has had the mission to provide state-of-the-art information on accessible information technology to schools, universities, libraries and business. Information on EASI's courses is on the web at http://easi.cc/workshop.htm where there are links to all course syllabi and to online registration. EASI provides scholarships to students, to overseas participants and also has a limited number of internships.
Information technology is becoming integrated into almost every college course and similar trends are taking place in K-12 and, of course, in business training. E-learning is no longer a matter of distance learning. Distance learning technologies are now part of most onsite courses. As these systems become increasingly accessible to learners with disabilities, the playing field will be more equal than ever before. The national Center for Accessible E-learning intends to be a one-stop information location on the web for those who need to learn about accessibility.
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