Universal Design for Learning and Digital Accessibility: Compatible Partners or a Conflicted Marriage?

Universal design for learning (UDL) and digital accessibility both seek to increase learning access and reduce barriers for students. As such, their primary goals are compatible and are widely acknowledged as crucial to ensuring equity in education. Indeed, the EDUCAUSE Learning Initiative (ELI) recognized their importance, ranking UDL and accessibility together as the No. 2 Key Issue in Teaching and Learning for 2018. However, while the intent of the two frameworks is the same, their scope and methods often vary considerably, which—when coupled with external influences—creates challenges and conflicts in their otherwise compatible aims.

UDL is a teaching and course-development framework that gives all individuals equal opportunities to learn. UDL emphasizes flexible approaches to instruction and content presentation, which make it easier for students to customize and adjust content to suit their individual learning needs. While UDL aims at a broad range of learners, digital accessibility focuses on learners who have particular needs related to sensory, physical, and/or cognitive impairments. This often involves coupling content presentations with accommodations to make them accessible to all users—for example, providing text versions of image-based content, which allows a screen reader to interpret that content for students with visual impairments.

Conflicts arise, however, because accessibility accommodations can sometimes complicate efforts to quickly disseminate flexible learning options to a broad student population. In some cases, institutions are responding to such conflicts in extreme ways. For example, one institution simply took down large volumes of online content that had been provided in the spirit of UDL but that did not meet accessibility standards; in other instances, colleges and universities that feel overwhelmed by a conflict have done nothing at all to address it.

To further the aims of both UDL and accessibility, we provide specific recommendations for institutions and faculty to help them follow accessibility guidelines while continuing to ensure that UDL content is available to the broadest possible student population. To succeed in these efforts, it is essential to first gauge your institution's cultural climate, deliberate all options, encourage whole campus involvement, and use the accessibility effort as an opportunity to improve—rather than reduce—UDL practices.

The Union of UDL and Digital Accessibility

Although UDL practices promote accessibility standards, a lack of resources for and knowledge about how to make UDL practices accessible can create conflict in these practices—such as prohibiting the UDL practice of lecture capture recordings when they do not include the accessibility practice of accurate captions. To find our way forward, it is crucial to understand the regulatory context as well as the compatibilities and conflicts in the UDL and accessibility relationship.

The Context: Accessibility Regulation and Response

Section 508, added in 1998 to the Rehabilitation Act of 1973, mandates digital accessibility—that is, federal agencies, contractors, and fund recipients must make their electronic and information technology accessible to people with disabilities. Higher education institutions have increased their attention to Section 508 compliance in light of a recent wave of complaints filed with the Office of Civil Rights (OCR). While a few institutions have been required to dedicate staff and services to completely overhaul their websites and instructional content, most have come to an agreement with OCR to comply with Section 508.

Compatible Partners?

UDL and digital accessibility standards have similar goals. Some proponents view UDL as a social justice model that enhances student success opportunities for all learners.¹ While UDL practices may not eliminate the need for individual accessibility accommodations, they may reduce that need.² UDL also shows promise for increasing persistence and retention for a broad range of students, including underrepresented minorities, non-proficient readers, English language learners, nontraditional students, working students, parents, and commuters.³ UDL achieves this by encouraging proactive and intentional course design that focuses on providing multiple ways to motivate students (engagement), present concepts (representation), and allow students to demonstrate their learning (action and expression).

Further, an accessibility mindset often leads to a universal design, resulting in benefits for people beyond those in need of a specific accommodation. For example, the ramps and wheelchair access installed to comply with the 1990 Americans with Disabilities Act (ADA) were created for individuals with limited mobility, yet anyone who has pulled luggage, pushed a stroller, or juggled an armful of books has benefited from this advancement. The same universal benefits are possible in the digital world with UDL and accessibility acting as partners, proactively designing learning environments that meet the needs of diverse learners.

Conflicted Marriage?

While similar goals make UDL and accessibility efforts compatible, technological limitations can pit them against one another in the short term. Technology tools—such as presentation software that lets you add graphics, video, and audio to text files—are often integral to UDL practices but may fail to meet accessibility standards.

For now, one of the main sources of conflict for UDL and digital accessibility is the relationship between image- and text-based instructional content. Digital accessibility standards require a text alternative to image-based media: captions and transcripts for videos, and "alt text" (that is, text descriptions) for images in slides and documents. This conflict can become particularly intense for institutions that are short on the time, resources, and knowledge required to meet accessibility standards or for those that simply react hastily to impose the standards and abandon UDL in the process.

Further, many of the faculty members who readily embrace UDL-friendly tools and technologies are concerned about web accessibility issues in relation to the materials they have already created. These issues include concern over the time and resources involved in updating their existing content, as well as the learning curve required to execute those updates. Also, given the continuing lack of compliance for many tools, this conflict can act as a strong deterrent for instructors considering UDL before they ever create any UDL content and see its value for students.

Key Compatibility Challenges and Recommendations

Instructional videos and image-based media, such as photos and graphs, are two UDL practices that can meet digital accessibility challenges.

Instructional Video

Lecture-capture recordings are a staple UDL strategy. These video and audio recordings of instructors and what they display on the screen (such as slides and demonstrations) let students review instructional content at their own time and pace; this helps students who

• are English language learners,
• have difficulty taking notes while listening to lectures,
• cannot attend class due to illness or work demands, or
• are having difficulty understanding an instructor's accent.

It also helps all students prepare for tests and assignments, particularly those involving complex terminology and concepts.

Research shows that students who review lecture recordings better retain and understand the material;⁴ such reviews might be especially beneficial for low-achieving students.⁵ Using videos, including short instructional videos,⁶ is an effective pedagogical approach for online or hybrid teaching⁷ that not only improves the lecture experience but also allows more class time for active learning and engagement.

While many students benefit from video instruction, videos that do not include captions and transcripts can be a significant barrier for students with disabilities. For example, blind students cannot see the math equation being explained and deaf students cannot hear the lecture content. For these students to participate in the course, prerecorded video content must at least include captions and transcripts—and, ideally, audio descriptions of any visual elements not described.⁸

UDL supports the use of captions and transcripts, as all students reap benefits from their use, including the benefits of

• language reinforcement,
• concept review, and
• improved understanding when watching videos in loud or otherwise chaotic environments.

Practically, however, creating captions and transcripts entails significant resource challenges, especially for existing video content. For short, simple instructional videos, resource needs might be manageable, but in any case, faculty must contend with the "triple constraint"—that is, good, cheap, fast—pick two. YouTube, for example, offers a cheap and fast option for captions, but the transcriptions are far from perfect. In particular, difficult terminology and words from speakers with accents are often incorrectly transcribed. The need for captions and transcripts is also particularly challenging for recordings of long lecture sessions. Although many vendors offer captioning and transcription services, using them can be expensive (that is, good and fast, but not cheap), and many institutions simply cannot afford them.

Further, many vendors have yet to update their products with accessibility features that meet the World Wide Web Consortium's Web Content Accessibility Guidelines (WCAG) and other standards. Vendors of these tools often offer Voluntary Product Accessibility Templates (VPATs), along with plans to increase accessibility, although some have yet to offer solutions to their product's accessibility shortcomings. This situation is similar to what the auto industry faced when fuel-efficiency laws were passed that outpaced industry capability. Such conflicts between accessibility standards and tech-based UDL strategies can render otherwise compatible educational practices temporarily incongruent.

There is also the challenge of deciding who is responsible for implementing accessibility standards:

• Who will create accurate closed-captioning and transcripts for all recorded lectures and videos?
• Can faculty be expected to do this? If so, do they have the time, skills, and resources required?
• Do we have funding available to outsource this responsibility?
• How do we prioritize our time and resources to comply with these standards?

If institutions are required to caption all video content, such videos—which benefit the majority of students⁹—could be eliminated if they are not updated immediately to meet the needs of the approximately 10 percent of the US population with disabling impairments.¹⁰ While most colleges and universities are in a position to avoid such drastic measures, even a few such stories, if widely publicized, could intensify the conflict between UDL and accessibility rather than focusing on how UDL and accessibility should work together.

Instructional Images

Another key UDL practice is "representing" instructional content through image-based media, such as photographs, graphs, and charts. As with video, accessibility standards require that images include a text-based equivalent. For students, pictures truly can be "worth a thousand words," as many people learn better when viewing information visually in charts, graphs, or pictures than they do from reading text alone, particularly when that text is complicated or overly detailed.¹¹

Accessibility standards do not discourage image use in educational content, but they rightly point out that, lacking a text alternative, such content is rendered invisible to students with severe visual impairments. However, instructors might find themselves paralyzed when attempting to create text alternatives for complex or abstract images: What is the text equivalent of a color-coded, multidirectional diagram of the human body? A line of music notes? A painting for texture analysis?

Accessibility proponents oppose the idea that standards will render educational content void of color, image, and creativity, but this perception persists when faculty members feel they must immediately compose a text description for every image they use. Accessibility champions are developing helpful resources and creative solutions for making image-based content accessible for all, including free tools for building accessible tables and guides for inclusive art instruction.¹² However, such developments do not necessarily soothe the tension of faculty members who rely on visual-based instruction, as these resources require time to learn and implement.

The risk here is that, faced with the need to describe each chart or other image they use, instructors might move away from image-based instruction and rely more heavily on traditional narrative text. In some cases, such a move would disadvantage students with "limited cognitive, language, and learning abilities," who were included in the Section 508 updates in January 2018. Research has found, for example, that students with learning disabilities do better using graphic organizers¹³ and that images can help students who struggle with complicated vocabulary and language variations.¹⁴

UDL best practices address this dilemma of visual versus narrative format in the principle of providing multiple means of representation—that is, offering instructional content in text and image form. Guided by this principle, instructors offer materials in multiple formats—one highlighting charts, graphs, and other visuals and another using text descriptions of these visuals. Accessibility proponents champion this approach as well. In reality, however, faculty and staff do not yet have the tools to consistently provide multiple formats. Compliance by both vendors and institutions will require time, skills, and resources.

This issue raises several questions:

• How can we ensure that faculty use images and provide useful accompanying text descriptions?
• How can institutional leaders support faculty members so that they accept, rather than resist, these necessary changes?
• Will recommended accessibility practices be revised to prioritize the use of visuals to address the learning needs of individuals with cognitive impairments?

Table 1 offers an overview of these challenges, which we now describe in more detail.

Table 1. UDL and Digital Accessibility Practices, Conflicts, and Recommendations

Technology	UDL Practice	Digital Accessibility Standard	Current Law	Recommendations
Lecture-capture recordings	Encourage faculty to record lectures so that diverse learners can review lecture content.	Create closed captions and transcripts for all lecture recordings.	Post only those recordings that meet the accessibility standard, removing recordings that do not comply.	Use appropriate closed captioning/transcript vendors when possible. Prioritize resources to pay for these vendors. Consult Disability Support Services for resources and recommendations. Use free or low-cost services such as YouTube and then review and correct. Work toward compliance for future recordings and develop a plan to address older ones.
Instructional video	Encourage the use of video to give diverse learners multiple ways to access content.	Create closed captions and transcripts for all lecture recordings.	Post only videos that meet the accessibility standard, removing recordings that do not comply.	Use free or low-cost services such as YouTube and then review and correct. Work toward compliance for future recordings and develop a plan to address older ones.
Image-based instructional content	Encourage the use of visuals, images, and charts.	Include text equivalents for visual media.	Include only visuals, images, or charts that have alternative text.	When possible, provide a range of formats—including ones with narrative text as well as visuals. Use alt text and an accessibility checker when possible.
Slide presentations and documents	Use slides and handouts to display instructional and house multimodal content, as well as to guide class activities.	Use legible font (size, type), sufficient color contrast, heading styles to organize sections, and an accessibility checker to flag problematic features.	Use only material that meets all accessibility standards.	When creating new materials and resources, use formats that pass an accessibility check. Over time, update older versions of materials to comply with accessibility.

Recommendations: Waiting Out the Waves

Initiatives launched under legal pressure can make educators feel like they must address all issues immediately, but this is often not the case. It's important to ask—particularly during moments of buzzing frenzy—when final decisions on accessibility standard implementation are needed, as well as the circumstances under which such decisions might change.

As accessibility law changes and evolves, the urgency could change from semester to semester. For now, we recommend waiting out the waves of accessibility standards implementation. Discuss implementation options with university stakeholders, but resist locking onto an approach until your institution's leadership has solidified a definite plan and enacted accountability measures. Throughout the often lengthy process of determining an accessibility action plan, your university may consider everything from requiring accurate captions for every video within the next year to encouraging best practices and collecting data on gradual standard adoption. Although it is important to hold discussions, we recommend waiting as long as necessary before locking into a specific plan; doing so avoids having to change training material and messages to faculty, such as whether accessibility implementation is "required" or "recommended." As the following recommendations show, we suggest that institutions focus not on letting legal compliance drive change but rather on implementing best practices grounded in success for all students.

Institutional Recommendations

To help ensure that your institution makes progress on both UDL and accessibility compliance, we offer the following recommendations.

1. Secure institutional leaders' support and commitment. Some institutions have an Office of Accessibility that oversees and supports the institution's transformation as it moves toward compliance; others have invested significant resources in a robust cadre of instructional designers or accessibility coaches to help faculty implement accessibility standards. Both models demonstrate a commitment to change, but even institutions that lack resources can demonstrate this commitment through support and communication from the executive leadership. For UDL and accessibility-related change initiatives to succeed, institutional leadership is critical—especially in terms of aligning initiatives with the values of inclusion.

2. Avoid the "fool's choice." Accessibility measures should have some sense of urgency, but they also need a feasible action plan. Avoid letting the fool's choice—that is, believing you have only two unfavorable approaches to a problem—creep into accessibility discussions and instead ferret out a favorable third, fourth, or fifth option. Typically, good options avoid extremes, such as sticking one's head in the sand or locking down any web content less than 100 percent compliant with standards.

3. Identify and recruit key institutional players. Regardless of the resources available, institutions that endorse UDL and accessibility must identify key players who can promote accessibility as a UDL ally. Teaching and learning centers (TLCs) and e-learning and instructional support offices can play important roles in assessing institutional climate and promoting a happy marriage between UDL and digital accessibility. Bring together distributed leaders who can make an action plan for accessibility that identifies small wins, translates accessibility for faculty needs, redirects conversation toward diversity and inclusion, and facilitates campus-wide communication and learning opportunities.¹⁵

4. Include training in your initiative. With collaboration and leadership in place, TLCs and e-learning offices can work together to create an initiative to support faculty in implementing UDL and accessibility. For such initiatives to succeed, training, workshops, consultations, and resources on both UDL and accessibility should be made available for all.

5. Adopt a social justice model uniting UDL and accessibility with other student success initiatives. Create a culture that supports students with diverse learning and life needs. A social justice model supports equal opportunity for all students, especially historically disadvantaged groups. Although institutions must comply with ADA and Section 508, accessibility can go beyond the law to embrace critical values and beliefs about diversity and social justice.

6. Cultivate a supportive rather than punitive approach to accessibility improvement. Avoid threats to police or take down digital content that does not yet meet all accessibility standards. Using legal pressures may be an incentive to secure funding and resources for accessibility, but it does not enhance faculty buy-in, morale, or commitment. Rather than using the terminology of compliance, promote ongoing progress that demonstrates a commitment to continual improvement.

7. Acknowledge that conflicts stem in part from growing pains in law and industry. Legislation, interpretation of the law, and practices continue to emerge and change. Over time, vendors will develop products that comply with the laws and are more effective and efficient. Educational technology will likely improve its ability to interpret image-based media to screen readers without faculty involvement. In the meantime, effective implementation typically takes longer than passing a law. Accepting this reality can help prioritize institutional efforts and determine how vendors might help with accessibility efforts.

8. Accept that change takes time. Transformation of a culture and practice takes time. Institutions and leaders must not only learn about these issues but also find resources, train faculty and staff, and implement the practices.

9. Be mindful of limits on faculty time, knowledge, skills, and resources. Make training and resources easily available for faculty and staff, including resources offered through CAST, the UDL Center, and EDUCAUSE. Also, it's important to simplify guidelines and resources, as the actual standards themselves can be overwhelming. To support progress, provide training, consultations, learning communities, practice, and ongoing conversations.

10. Identify champions and resistors. Listen to and engage with both supporters and detractors of these changes. The champions, much like early technology adopters, can serve as mentors and role models for others. It is equally important to listen to resistors and develop a plan to address their concerns and offer support for their challenges.

Faculty Recommendations

1. Seek out training and resources to learn about UDL and accessibility. Reviewing web standards can be overwhelming, but if your own institution does not have UDL and accessibility resources, focus on those from other colleges and universities. First, focus on simple yet essential accessibility features such as text formatting, the use of color, descriptive web links, and heading styles. Next, gain an understanding of standards for text alternatives to image- and audio-based material, including video captions and image and table descriptions.

2. Focus on a social justice model to enhance student success for diverse learners. Is your course inclusive for students of varying abilities and different learning and life needs? Remove any barriers to your content so that your students can focus on learning.

3. Join a learning community. Get involved in a cohort or learning community that lets you share ideas and resources.

4. Start slowly. Rather than updating all of your old course materials, begin by setting a goal to embed accessibility and UDL into newer versions of digital work.

5. Prioritize—and know your limitations. Begin with simple changes that you feel comfortable with and build from there.

6. Collaborate to support students who need individual accommodations. If you have a student who is blind, deaf, or has limited mobility, work with Disability Support Services to translate course materials, design alternative and equivalent assessments, and ensure that the environment is conducive to the student's learning. Even simple, proactive measures—such as offering early syllabus access and textbook orders—can have a significant positive impact on this accommodation process.

7. Use available accessibility tools. Find creative and resourceful solutions, such as using free and low-cost programs or applications and providing course materials in alternative formats (a UDL approach).

8. Identify your current UDL and accessibility practices. Focus on what you are already doing, as some effective teaching practices may already embrace UDL principles. Also, it can be helpful to reflect on how accessibility standards could improve your UDL strategies.

9. Provide content in multiple formats. Rather than remove visual forms of representation from your course content, add additional formats or alt text when possible.

10. Use free captioning options. If you do not have access to lecture captioning services, try using YouTube or another free service, and then review the recording to correct mistakes.

Creating a Cultural Shift

To make an initiative last beyond any one societal movement, political era, or legal decision, a cultural shift is required. To get there in this case, institutions must focus on student success initiatives that promote both UDL and accessibility—such as a commitment to captioning most instructional videos, which helps all students.¹⁶ Such initiatives can guide our institutions toward making accessibility "the way we do business" rather than simply being a set of policies that we try to keep up with.

Further, because change initiatives require broad involvement, it is crucial to consider how our institutional recommendations might work in your own corner of academia and then use the second set of recommendations to bring faculty into the accessibility effort.

Every meaningful relationship requires communication, time, and effort to ensure that it stays strong and vital, and every partnership faces challenges and conflicts. However, if it is something of value and importance—such as the commitment to support inclusivity and social justice through UDL and digital accessibility—working through these challenges and conflicts is worth the effort.

Notes

1. Universal Design for Learning Guidelines, National Center on Universal Design for Learning, 2018; Susan Joan Courey, Phyllis Tappe, Jody Siker, and Pam LePage, "Improved Lesson Planning with Universal Design for Learning (UDL)," Teacher Education and Special Education 36, no. 1 (2012), 7–27; Heather W. Hackman, "Broadening the Pathway to Academic Success: The Critical Intersections of Social Justice Education, Critical Multicultural Education, and Universal Instructional Design," in Pedagogy and Student Services for Institutional Transformation: Implementing Universal Design in Higher Education, Jeanne L. Higbee and Emily Goff, eds. (Minneapolis: University of Minnesota Press, 2008); and Kavita Venkatesh, "Universal Design for Learning as a Framework for Social Justice: A Multicase Analysis of Undergraduate Preservice Teachers" (PhD diss., Boston College, 2015). ↩
2. Because some UDL and digital accessibility standards are the same, implementing UDL guidelines could reduce the need for separate accessibility-related accommodations. The WCAG success criteria often require "alternative formats" in order for people with impairments to have multiple ways to consume content if one format doesn't work for them (an example is text alternatives, such as captions or transcripts, for video content). Similarly, Checkpoint 1 for the UDL guideline of "multiple means of representation" calls for providing "options for perception." ↩
3. Dave Edyburn, "Harnessing the Potential of Technology to Support the Academic Success of Diverse Students," New Horizons for Higher Education 2011, no. 154 (Summer 2011), 37–44; and Thomas J. Tobin, "Increase Online Student Retention with Universal Design for Learning," Quarterly Review of Distance Education 15, no. 3 (2014), 13–24. ↩
4. Jovan F. Groen, Brenna Quigley, and Yves Herry, "Examining the Use of Lecture Capture Technology: Implications for Teaching and Learning," Canadian Journal for the Scholarship of Teaching and Learning 7, no. 1 (2016). ↩
5. Ron Owston, Denys Lupshenyuk, and Herb Wideman, "Lecture Capture in Large Undergraduate Classes: Student Perceptions and Academic Performance," The Internet and Higher Education 14, no. 4 (2011), 262–268. ↩
6. Philip Guo, "Optimal Video Length for Student Engagement," edX Blog, November 13, 2013. ↩
7. A.W. (Tony) Bates, "Pedagogical Roles for Video in Online Learning," blog, March 10, 2012; and Elisabeth Leonard, Great Expectations: Students and Video in Higher Education (Thousand Oaks, CA: SAGE Publications, 2015). ↩
8. The World Wide Web Consortium's Web Content Accessibility Guidelines 2.0 offer standard guidelines used to interpret compliance with Section 508 of the Rehabilitation Act. For guidelines specific to video, see "Audio Description or Media Alternative (Prerecorded)," Level AA, World Wide Web Consortium. ↩
9. Edyburn, "Harnessing the Potential of Technology"; Anne Meyer, David Rose, and David Gordon, Universal Design for Learning: Theory and Practice (Boston: CAST Professional Publishing, 2014); and Tobin, "Increase Online Student Retention." ↩
10. The number of people who have disabling visual, hearing, or mobility impairments is difficult to calculate because definitions of "disabling" vary. However, the National Federation of the Blind estimates that 2.5 percent of people have a profound visual impairment, while the National Institute of Deafness and Other Communication Disorders estimates that, of US adults, 2.5–8.5 percent have "disabling hearing loss." ↩
11. Eliza Bobek and Barbara Tversky. "Creating Visual Explanations Improves Learning," Cognitive Research 1, no. 1, (2016), 27; and Ghulam Shabiralyani, Khuram Shahzad Hasan, Naqvi Hamad, and Nadeem Iqbal, "Impact of Visual Aids in Enhancing the Learning Process Case Research: District Dera Ghazi Khan," Journal of Education and Practice 6, no. 19 (2015), 226–233. ↩
12. Among these tools are Accessify's Table Builder and Art Beyond Sight. ↩
13. Douglas Dexter and Charles Hughes, "Graphic Organizers and Students with Learning Disabilities: A Meta-Analysis," Learning Disability Quarterly 34, no. 1 (2011), 51–72. ↩
14. Peter Blanck, "The Struggle for Web eQuality by Persons with Cognitive Disabilities," Behavioral Sciences and the Law 32, no. 1 (2014), 4–32. ↩
15. Adrianna Kezar and Peter Eckel, "Examining the Institutional Transformation Process: The Importance of Sensemaking, Interrelated Strategies, and Balance," Research in Higher Education 43, no. 3 (June 2002), 295–328. ↩
16. Katie Linder, Student Uses and Perceptions of Closed Captions and Transcripts: Results from a National Study (Corvallis, OR: Oregon State University Ecampus Research Unit, 2016). ↩

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Judith Ableser is Director of the Center for Excellence in Teaching and Learning (CETL) at Oakland University.

Christina Moore is Virtual Faculty Developer in the Center for Excellence in Teaching and Learning at Oakland University.