2003 Conference Proceedings

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Joel Sanda
Standards & Accessibility Consultant
Email: joels@ecollege.com

The information presented in this White Paper is not intended to be, and does not constitute legal advise regarding any of the topics contained herein.

This white paper discusses how campus-wide implementations of accessible eLearning platforms can reduce the cost of compliance with existing disability law. After briefly discussing existing accessibility laws and their application to eLearning I review eCollege's three-year research project to deliver an accessible eLearning platform that is accessible and can be integrated with on-campus teaching.

This paper's thesis is:

Colleges and universities implementing compliant and accessible eLearning programs can extend the usefulness of such programs into the on-campus environment and mitigate the costs associated with educating learners with disabilities.

This paper, and eCollege's implementation of accessibility features, defines accessibility as:

The ability for all users to enjoy the same level of access to and interaction with eLearning course content, features, instructors, and learners using readily available assistive technologies.

Though eCollege embraced the implementation of Section 508 of the Rehabilitation Act, and developed solutions that comply with those requirements, our focus has been and is on how users of assistive technology access the Internet and Web.

Educational institutions face a multitude of accessibility laws today. Charged with educating all users regardless of disability, the profusion of U.S. State and U.S. Federal laws has led to the development of on-campus offices and bureaucracies meant to ensure all students have unfettered and equal access to educational opportunities.

Disabled Student Services (DSS) offices, charged with ameliorating these problems, are often faced with just-in-time problem solving. Textbooks, lectures, classroom handouts, and examinations can all present barriers for some learners. DSS offices must convert inaccessible content or re-create testing events to ensure a learner's disability does not become a mitigating factor in student learning. Though costly, these efforts at making inaccessible course content, pedagogies, and student services accessible to the disabled are necessary to ensure students have equal access to educational opportunities. Failure to do so places the college or university in the unfortunate and costly situation of creating a civil rights violation.

This paper will demonstrate that accessible eLearning presents an opportune moment in the history of education and learners with disabilities. Campus-wide eLearning coupled with modern assistive technologies can:


Section 508 (1194.22) of the Rehabilitation Act in many ways bridges that part of the 'digital divide' faced by people with disabilities. Built in part upon the work by the W3C's Web Accessibility Initiative, Section 508 is the first legally binding specification defining the accessibility of web-based applications available. The Architectural and Transportation Barriers Compliance Board ("The Access Board")

... developed standards for electronic and information technology under the Rehabilitation Act Amendments of 1998. Section 508 of the Rehabilitation Act Amendments requires that when Federal departments or agencies develop, procure, maintain, or use electronic and information technology, they shall ensure that the technology is accessible to people with disabilities, unless an undue burden would be imposed on the department or agency. [I]

While Section 508 applies to the procurement, development, maintenance and use of Electronic Information and Technology (EI&T) by U.S. Federal Agencies, its application to the U.S. educational sector is logical and carries the weight of historical and legal merit. Educational institutions in the U.S. today must wade through a litany of legislation and requirements ensuring they are barrier free for people with disabilities. A quick survey of these laws produces the following list:

Nearly all educational institutions must already comply with Section 504 of the Rehabilitation Act ("Section 504") and Title II of the Americans with Disabilities Act of 1990 ("ADA"), which are enforced by the Office of Civil Rights. The Office of Civil Rights argues:

Virtually all public school districts are covered by Section 504 because they receive some federal financial assistance. Public colleges and universities generally receive federal financial assistance, and most private colleges and universities receive such assistance. [ii]


Section 508 is critical to U.S. educational institutions because nearly all must comply with Title II of the ADA and Section 504. Since these laws require unfettered access to college and university programs by the disabled, EI&T is likely covered under existing law. The best measure for this, and the most easily implemented by educational institutions, is Section 508.

Compliance with Section 508 can ensure, among other things, learners and instructors have access to EI&T with today's off-the-shelf assistive technology. Compliance requirements under Section 504 and Title II require institutions to provide the same services and programs to the disabled as they do those without disabilities. Because of this Section 508 compliant EI&T can help ensure compliance with the larger requirements of Section 504 and Title II.

Integrating a Section 508 compliant and accessible campus-wide eLearning solution dissolves many of the problems facing the accessibility of on-campus education. Students with disabilities face inaccessible course handouts, class syllabi not easily converted to Braille, inaccessible lecture notes, and inaccessible in-class assessments. When these materials and services are made available first in an accessible format for all students an institution has gone far to reduce demands on DSS offices. By leveraging accessible eLearning solutions in a campus-wide implementation the institution not only enjoys the benefits of eLearning programs but also provides a mechanism for the distribution of accessible instructional materials and student services.

Campus-wide eLearning initiatives are providing, for the first time in the history of education, a ready path for the full desegregation of learners and instructors with disabilities. Such an implementation empowers students and instructors to publish their content on an accessible platform and assume the responsibility for their educational destiny. This not only empowers individuals to be successful instructors and learners but also relieves overstaffed DSS offices of the high costs of just-in-time problem solving.


Contrary to what some have argued, the cost of building accessible EI&T is higher than that of building inaccessible EI&T. Initial costs come with the need to establish software and organizational requirements as well as testing hardware and software for assistive technology. While AT vendors have come a long way in their support for accessibility specifications and integration with web browsers, problems still remain. Overcoming these limitations and AT rendering discrepancies, coupled with the conversion of older and/or non-compliant EI&T, can add significant expense to a college or university's information technology costs.

A second source of additional costs is found with programmatic objects such as interactive Java applets and multimedia presentations that require additional text-based content. This objects must be exposed with text-based alternatives that can require significant transcription and description in the case of multimedia presentations, significant code modification for compiled applets, or the addition of content that explains the interactivity and at least simulates interactive choices made by the end users.

Finally, existing technical support options must include provisions for supporting not only disabled users but also assistive technology. While the technical aspects of Section 508 typically do not stress the technological capabilities of experienced EI&T development groups, the associated costs of a new development, testing, and support paradigm can stress resources. Key costs follow:


eCollege invested nearly three years in the research and development of accessible eLearning solutions. This led us to meet with representatives from AT vendors, instructors and learners with disabilities, DSS office personnel, college I.T. personnel, and administrators concerned with the deployment of accessible solution in K-12 and higher education.

Our research identified critical stakeholders in today's educational settings. From the student struggling to obtain accessible learning materials and the overstaffed DSS offices to the senior administrators concerned with higher costs, the message was clear:

Accessible solutions that respect existing college and university pedagogies, enhance compliance with accessibility law, and integrate with today's learning environment are needed.

Armed with data collected from research conducted on our partners' campuses nationwide, AT vendors and at conferences, eCollege crafted an approach that implemented accessible EI&T without compromising educational rigor. This approach was both basic and simple: build an accessible eLearning platform that mitigates disabilities in the learners' educational experience. Much of our success followed from identifying disability not as a characteristic of the learner but as a problem whose solution can be informed by technological solutions. After all, it's not how a student reads and interacts in an online classroom but how the online classroom can be crafted to inspire the student to learn.

The result is an eLearning platform that integrates with leading consumer-oriented assistive technologies and uses the same platform for all users, regardless of disability. Extending this to on-campus learning is both awesome and should come as a relief to those struggling with the costs of educating people with disabilities. With available off-the-shelf technologies eCollege's solution considers assistive technology to be more critical to a learner's success than the learner's disability. We leverage existing AT solutions to solve the technical problems associated with the difference between visual and non-visual users. Rather than address students and learners as disabled, which is not always germane to educating and learning, eCollege's approach addressed the technologies used to ameliorate the effect of the disability. Whether a student reads lessons or has software synthesize the content audibly is moot: educating and learning are what's important.

This understanding - defining not the disability but identifying the assistive technologies in use today, allow us to solidly grasp the stakeholders in education today. Online or offline the mission is the same: introduce students to new ideas, challenge them, and sharpen their intellect and understanding of our world. Pedagogy knows only learners - not disability. The table below identifies these stakeholders, their immediate concerns, and how eCollege implemented a solution-focused response:

Table 1: Accessibility Stakeholders, Concerns, and eCollege Solutions Stakeholder

Student with a Disability

Instructor with a disability

Disabled Student Services (DSS) Office

I.T. & Computing Support Departments

Institution's Legal Department, Administrators & Executives


eCollege's accessibility implementation featured support for many accessibility challenges facing educational institutions today - both online and on-campus. Towards this end, the release of the College AU+ courseware platform not only provides colleges and universities with a Section 508 compliant eLearning platform, but also assists with the efforts to comply with Section 504 and Title II of the ADA both on-campus and online. Compliance measures include:

Integrating these traditionally online features with services normally offered in on-campus settings gives all students the convenience of taking courses online. And because accessible eLearning means paying attention to solving the technical issues surrounding accommodation the student is able to focus on his or her learning and not securing accommodations for inaccessible classroom learning requiring augmentation. Lectures for the deaf and hard of hearing can be read online and are not dependent upon scheduling classroom signers or transcribing speech to text. Paper-based exams, which are entirely inaccessible to people who cannot write with a pencil, are accessible to pointer devices and keyboard only users.

Perhaps the most immediate benefit afforded to colleges implementing an accessible campus-wide eLearning platform with a proven track record are the cost savings. Implementing the solutions provided by eLearning providers dedicated to developing accessible products and support services gives today's colleges and universities additional paths more options in being accessible. The benefits of centrally located and managed information and resources reduces additional on-campus expenses as well, while further enhancing existing compliance with disability law.


eCollege chose to approach the problem of accessible eLearning as a campus-wide problem. When understood this way accessible solutions not only become easier to implement but also serve to enhance and bolster existing organizational compliance with accessibility laws. This approach also identifies all stakeholders in the organization, which assists in organizational commitments necessary to assure campus-wide accessibility.

eCollege's implementation of Section 508 of the Rehabilitation Act went far beyond the minimum legal requirements for accessibility. A requirement agreed upon by the entire development team was to ensure all learners and instructors with disabilities could access the same content and course features set regardless of disability. However, some features, such as white board software, prove too dependent upon visual acuity to be made accessible to all users. To accommodate this, eCollege employs technology that supports white board sessions in conjunction with text messaging and voice over I.P. technologies, to ensure deaf and hard of hearing and blind and visually impaired students have access to the white board contents. We have also implemented technologies poised to take advantage of MathML, to ensure high-end mathematics and science courses remain accessible to non-visual users.

Success in such an endeavor can be measured in many ways, though perhaps two examples will suffice.

The first came in the form of an unsolicited phone call to eCollege from a student with learning disabilities. An undiagnosed learning disability led several colleges to dismiss him due to "poor academic performance". After being diagnosed with a learning disability he opted for a university using eCollege for on-campus courses as well as distance education. He was able to complete his degree using assistive technology that enabled him to read. His phone call and testimony energized the entire development team.

A second example comes from a participant in eCollege's internship program established with the Colorado Center for the Blind. This blind user supported sighted eCollege users over the telephone and via email. The bulk of support was instructing new computer users in the use of their eCollege hosted course. As such, most assistance involved walking students new to online education through the many features of our platform. We coined a term for this: "If you could see what I hear".

The disabled have long faced hurdles in obtaining equal access to higher education. Through our research, cooperation with advocacy groups, and field research dedicated to understating how the disabled use assistive technology to overcome hurdles. ECollege has taken a big step in the history of education and the disabled.

But, as we all know, the real history being made is when the learning disabled complete advanced degrees under their own volition after being previously dismissed for poor academic performance.

i Electronic Information and Technology. Section 508 of the Rehabilitation Act: Electronic and Information Technology Accessibility Standards, The U.S. Access Board. 03 September 2002. http://www.access-board.gov/sec508/status.htm.

ii Questions and Answers on Disability Discrimination under Section 504 and Title II. Office for Civil Rights, Department of Education. 03 September 2002. http://www.ed.gov/offices/OCR/qa-disability.html.

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