ADA Compliance for Online Course Design

A Growing Community

These and other colleges and universities have something in common:

• California Community Colleges
• California State University Fullerton
• Florida State University
• Harvard University
• Louisiana Tech University
• Maricopa Community College District
• Massachusetts Institute of Technology
• North Carolina State University
• Ohio State University
• South Carolina Technical College System
• University of California, Berkeley
• University of Cincinnati
• University of Colorado at Boulder
• University of Kentucky
• University of Montana–Missoula
• Youngstown State University

Each has had to resolve a civil rights complaint about the inaccessibility of its information technology, including technology used in online courses. The complaints are usually brought through the Office of Civil Rights of the U.S. Department of Education or the Civil Rights Division of the Department of Justice. Although the University of Washington has not received a civil rights complaint of this type, that has not stopped us from applying lessons learned from the cases involving other colleges and universities.

The Legal Basis for Civil Rights Complaints

The most common laws referenced in the resolutions are Section 504 of the Rehabilitation Act of 1973 [https://www.dol.gov/oasam/regs/statutes/sec504.htm] and the Americans with Disabilities Act of 1990, along with its 2008 amendments. These laws establish a firm legal basis for the requirement that IT procured, developed, and used by postsecondary institutions be accessible to individuals with disabilities. Together these statutes require that campus offerings — including those made available through applications software, websites, videos, PDF files, and other IT — be available to all students, faculty, staff, and visitors for whom they are designed, including individuals with disabilities.

The Meaning of "Accessible"

The definition of "accessible" used by the Office of Civil Rights and the U.S. Department of Education regarding inaccessible IT is as follows:

"Accessible" means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use. The person with a disability must be able to obtain the information as fully, equally, and independently as a person without a disability.¹

The Meaning of "Accommodation"

"Accommodations" are adaptations made for specific individuals when a product or service is not accessible, such as providing captions on a video only when a specific student who is deaf requests them rather than including them in the original product design. Among the most common accommodations made for students with disabilities in online courses are the addition of captions to videos for students who are deaf and the remediation of documents to make them accessible to students who are blind and use screen readers to access content or who have dyslexia and other learning disabilities that make reading easier when they can see printed words and listen to them spoken at the same time. Proactively developing, procuring, and using accessible software, websites, videos, documents, and other IT reduces the need for accommodations.

Strategies for Making Online Learning Accessible

Providing multiple ways for students to gain knowledge, demonstrate knowledge, and interact goes a long way toward making a course accessible to all students, including those with disabilities. It is also helpful to know a bit about the thousands of assistive technologies that people with disabilities might use to provide input to the computer and gain access to the output. You do not need to be familiar with all of the capabilities of these devices, but it is important to know how they are used and understand some of their limitations.

For example, screen readers have the capabilities to skip from link text to link text in a web page and from heading to heading in a document. These features allow individuals who are blind to skim through a web page to find resources that are linked from the page and through a document to gain an overview of its content and organizational structure. These functions are only useful if web document creators make the text of links meaningful (for example, "DO-IT newsletter" rather than "click here") and appropriately structure headings (for example, using the Style feature of Microsoft Word so that the screen reader knows what text forms a heading).

Table 1 summarizes how accessible practices can be developed in response to limitations of assistive technologies.

Table 1. Adding accessible functions to assistive technologies

Assistive Technology Limitation	Solution
Emulates the keyboard but may not fully emulate the mouse	Design websites and software to operate with the keyboard alone
Cannot read content presented in images	Provide alternative text
Can tab from link to link	Make links descriptive
Can skip from heading to heading	Structure the content with hierarchical headings
Cannot accurately transcribe audio	Caption video and transcribe audio

Tips for Teaching an Accessible Online Course

I taught the first online learning course at the University of Washington in 1995. My co-instructor, Norm Coombs, is blind. We designed the course to be accessible to students who had a broad range of challenges, including those related to vision, hearing, learning, attention, and mobility. We employed the latest technology of the time — e-mail, discussion list, Gopher, file transfer protocol, and Telnet. All online materials were in a text-based format, and videos — which were mailed to the students — were presented in VHS format with captions and audio description.

When asked how many of the students in this course had disabilities, we were proud to say that we did not know. No one needed to request disability-related accommodations because of the accessible design of the course. We offered the class many times over the course of a few years; no student requested an accommodation, even though we knew from voluntary disclosures that some of them were deaf, some were blind, and some had disabilities related to reading. Our accessibility efforts benefited not only students with disabilities but also students who are English language learners and those working in either noisy environments or quiet settings, such as a library where others are working or a dorm room when a roommate is sleeping. Accessible instructional design is good instructional design.

Although the technology today is more advanced and diverse, the basic issues are the same when it comes to accessibility. Faculty and instructional designers need to make sure that screen readers can access content in a text-based format; that content is accessible by using the keyboard alone; that videos are captioned; that content is presented in a clear, consistent, structured format; and so on.

From my experiences teaching online, I have developed a list of 20 tips — with references to in-depth resources for some of the topics — that can help online instructors make their courses accessible to a broad audience: "20 Tips for Teaching an Accessible Online Course." Although the tips do not cover every potential accessibility issue, they provide a good start.

For course web pages, documents, images, and videos:

1. Use clear, consistent layouts and organization schemes for presenting content.
2. Structure headings (using style features built into the learning management system, Word, PowerPoint, PDFs, etc.) and use built-in designs/layouts (e.g., for PPT slides).
3. Use descriptive wording for hyperlink text (e.g., "DO-IT Knowledge Base" rather than "click here").
4. Minimize the use of PDFs, especially when presented as an image; make sure the text is accessible by testing to see if you can copy and paste it. Always offer a text-based alternative as well.
5. Provide concise alternative-text descriptions of content presented within images.
6. Use large, bold fonts on uncluttered pages with plain backgrounds.
7. Use color combinations that are high contrast and can be read by those who are colorblind.
8. Make sure all content and navigation is accessible using the keyboard alone [http://www.uw.edu/accessibility/web/].
9. Caption or transcribe video and audio content.

With respect to instructional methods:

10. Assume students have a wide range of technology skills and provide options for gaining the technology skills needed for course participation.
11. Present content in multiple ways (e.g., in a combination of text, video, audio, and/or image format).
12. Address a wide range of language skills as you write content (e.g., spell out terms rather than relying on acronyms alone, define terms, avoid or define jargon).
13. Make instructions and expectations clear for activities, projects, and assigned reading.
14. Make examples and assignments relevant to learners with a wide variety of interests and backgrounds.
15. Offer outlines and other scaffolding tools to help students learn.
16. Provide adequate opportunities for practice.
17. Allow adequate time for activities, projects, and tests (e.g., give details of project assignments in the syllabus so that students can start working on them early).
18. Provide feedback on project parts and offer corrective opportunities.
19. Provide options for communicating and collaborating that are accessible to individuals with a variety of disabilities.
20. Provide options for demonstrating learning (e.g., different types of test items, portfolios, presentations, discussions).

Clearly, design of an accessible course involves considerations related to both IT accessibility and pedagogy.

Benefits of Accessible Design for Individuals without Disabilities

Students in a class can vary by gender, race, ethnicity, culture, marital status, age, communication skills, learning abilities, interests, physical abilities, social skills, sensory abilities, values, learning preferences, socioeconomic status, religious beliefs, and other factors. Many of these individuals might never request a disability-related accommodation but will nevertheless benefit from accessible design. For example, many English language learners benefit from captions on videos so that they can see the spelling of new vocabulary. Other students learning new vocabulary in a technical class can benefit from these captions as well. And everyone benefits from course content that is presented in a logical, consistent manner.

Note

1. See "Resolution Agreement: South Carolina Technical College System, OCR Compliance Review No. 11-11-6002."

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Sheryl Burgstahler is the director of Accessible Technology Services within UW-IT and affiliate professor in the College of Education at the University of Washington.