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A litigation and legislative strategy for making e-accessibility the default in American post-secondary education BrailleNet Presents: 9 th European e-Accessibility Forum e-Accessible Knowledge 8 June 2015 Cite des sciences et de lindustrie


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A litigation and legislative strategy for making e-accessibility the default in American post-secondary education

BrailleNet Presents: 9th European e-Accessibility Forum e-Accessible Knowledge 8 June 2015 Cite des sciences et de l’industrie – Universcience – Paris Daniel F. Goldstein, Esq.

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“[t]he “information superhighway is fast becoming a fundamental tool in post-secondary research. Rather than implementing adaptive software, some institutions…utilize personal attendants as the exclusive

  • r primary way of making…computer information

accessible to blind persons… In most cases, this approach should be reconsidered. An appropriate auxiliary aid…[can] foster independence and autonomy in the person with a disability. Letter to Dr. Robert Caret (1/25/1996): http://www.icdri.org/legal/sjsu.htm

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 When reasonably priced technology is available that will enable the visually

impaired computer user to access the computer, including the World Wide Web, during approximately the same number of hours with the same spontaneous flexibility that is enjoyed by other nondisabled computer users…the objectives of Title II will most effectively and less expensively be achieved by obtaining the appropriate software programs.”

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Letter to Dr. Robert Caret (1/25/1996): http://www.icdri.org/legal/sjsu.htm

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“[w]hen making purchases and when designing its resources, a public entity is expected to take into account its legal obligations to provide communication to persons with disabilities that is “as effective as” communication provided to nondisabled persons. At a minimum, a public entity has a duty to solve barriers to information access that the public entity’s purchasing choices create, particularly with regard to materials that with minimal thought and cost may be acquired in a manner facilitating provision in alternative formats.

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 When a public institution selects software programs and/or hardware

equipment that are not adaptable for access by persons with disabilities, the subsequent substantial expense of providing access is not generally regarded as an undue burden when such cost could have been significantly reduced by considering the issue of accessibility at the time of the initial selection.”

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Letter to Dr. James. Rosser, President (4/7/1997): http://www.icdri.org/legal/csula.htm

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The University did not provide the complainant access to alternative media educational materials in the same time frame as educational materials are available to non-disabled students. The delays in receiving alternative media materials had a negative effect on complainant’s opportunities to achieve the same educational

  • pportunity, and (effective communication) as that afforded to non-disabled students.

Letter to Milton A. Gordon, Cal. State Fullerton (9/1/2003): www.galvin- group.com/media/48594/CA_OCR_CSU_Fullerton(1).pdf

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 The Agreement required, among other

significant issues critical to students with disabilities, implementation of detailed policies and procedures regarding the provision of access to materials in alternate format. Settlement Agreement (10/25/2004): http://www.dralegal.org/sites/dralegal.org/files/casefiles/settlement_2.pdf

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 iTunes U, a collaboration between Apple and various educational institutions,

accessed through the iTunes Store, provided free content by the educational institutions, including course lectures, language lessons, lab demonstrations, sports highlights and campus tours.

 Apple committed to providing Full and Equal Access to all information, interactions,

features, products and services of iTunes and iTunes Services (including the ability to locate and download iTunes software and updates from the Apple.com website or by other methods of distribution….)

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Press Release (9/26/2008): https://nfb.org/node/1117

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 The University affirmed its commitment to provide disabled students, including

blind students, with equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.

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 The University made a commitment that if it deploys any e-book reading device in

a class, it will choose a device (if commercially available, at a reasonable cost provided that the e-reader meets the requirements of the class) that allows the blind student to access and acquire the same information, engage in the same interactions, and enjoy the same services that the e-book reading device offers sighted individuals with substantially equivalent ease of use. Settlement (1/8/2010): http://www.ada.gov/arizona_state_university.htm

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 DOJ enters into additional settlement agreements with public and private colleges

and universities that used the Kindle DX as part of a pilot study with Amazon.com,

  • Inc. The universities and colleges agreed not to purchase, require, or recommend

use of the Kindle DX, or any other dedicated electronic book reader unless or until the device was fully accessible to blind individuals or those with low vision, or the university/college provided an accommodation or modification so that a student with a disability can acquire the same information, engage in the same interactions, and enjoy the same services as sighted students with substantially equivalent ease of use. Similar agreements were entered into with the Department of Education.

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 Settlement Case Western Reserve (1/13/2010):

http://www.ada.gov/case_western_univ.htm

 Settlement Pace University (1/13/2010):

http://www.ada.gov/pace_univ.htm

 Settlement Princeton University (3/29/2010):

http://www.ada.gov/princeton.htm

 Settlement Reed College (1/13/2010):

http://www.ada.gov/reed_college.htm

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  • The letter confirmed that requiring use of an emerging technology (an inaccessible

book reader) is discrimination prohibited by the ADA and Section 504 unless accommodations or modifications can be provided that permit the student with a disability to receive all the educational benefits provided by the technology in an equally effective and equally integrated manner.

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 The letter reminded private college and university presidents that Under Title III,

students with disabilities may not be discriminated against in the full and equal enjoyment of all of the goods and services of the college or university; students must receive an equal opportunity to participate in and benefit from these goods and services; that students must not be provided with different or separate goods

  • r services unless doing so is necessary to ensure that access to the goods and

services is equally effective as that provided to others.

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  • The letter reminded public university presidents that under Title II qualified

individuals with disabilities may not be excluded from participation in or denied the benefits of the services, programs or activities of, nor subjected to discrimination by the public university or college.

  • The letter went on to confirm that both Title II and Section 504 prohibit public

colleges/universities from affording individuals with disabilities with an opportunity to participate in or benefit from college and university aids, benefits, and services that is unequal to the opportunity afforded others. And, that, individuals with disabilities must be provided with aids, benefits, or services that provide an equal opportunity to achieve the same result or the same level of achievement as others.

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 DOJ told college and university presidents to refrain from requiring the use of

inaccessible book reader, or other technology, in a teaching or classroom environment, as long as the device remains inaccessible. DOJ states that “it is unacceptable for universities to use emerging technology without insisting that this technology be accessible to all students.”

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 “Technology is the hallmark of the future, and technological competency is essential

to preparing all students for future success. Emerging technologies are an educational resource that enhances learning for everyone, and perhaps especially for students with disabilities. Technological innovations have opened a virtual world

  • f commerce, information, and education to many individuals with disabilities for

whom access to the physical world remains challenging. Ensuring equal access to emerging technology in university and college classrooms is a means to the goal of full integration and equal educational opportunity for this nation’s students with

  • disabilities. With technological advances, procuring electronic book readers that

are accessible should be neither costly nor difficult.” U.S. Dept. of Justice Joint Dear Colleague Letter: Electronic Book Readers (6/29/2010): http://www2.ed.gov/about/offices/list/ocr/letters/colleague-20100629.html

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 The FAQ made clear that none of what it said in the June 29, 2010 letter was new law

but rather addressed key principles of federal discrimination law.

 The FAQ explained that the test for compliance is the functional definition of

accessibility reiterated in the Dear Colleague Letter: one can acquire the same information, engage in the same interactions, and enjoy the same services as sighted students with substantially equivalent ease of use. And, even if this does not result in identical ease of use, it must ensure equal access to the educational benefits and opportunities afforded by the technology and equal treatment in the use of such technology.

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 This same test applies to those with other print disabilities.  One purpose of the Dear Colleague letter was to remind universities of its

  • bligations when purchasing emerging technologies.

 Confirmation that the June 29, 2010 Dear Colleague Letter applies equally to

elementary and secondary schools.

 The Dear Colleague Letter applies to all school operations, including pilot programs

and to all faculty and staff.

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 Confirmation that the Letter applies to all school programs, whether in brick and

mortar, online (provided by the school or through contractual or other arrangement)

  • r other virtual context.

 Clear message that schools must plan for having accessible technology available

immediately upon a request; “the planning should include identification of a means to provide immediate delivery of accessible devices or other technology necessary to ensure accessibility from the outset.”

 Must consider accessibility when they are deciding whether to create or acquire

emerging technology, and when they are planning how the technology will be used. Accessibility must be part of acquisition procedures.

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 Questions that must be asked: What educational opportunities and benefits does

the school provide through the use of the technology? How does the technology provide these opportunities and benefits? Does the technology exist in a format that is accessible to individuals with disabilities? If the technology is not accessible, can it be modified, or is there a different technological device available, so that students with disabilities can obtain the educational opportunities and benefits in a timely, equally effective, and equally integrated manner? U.S. Dept. of Justice FAQ re: Dear Colleague Letter: Electronic Book Readers (5/26/2011):http://www2.ed.gov/about/offices/list/ocr/docs/dcl-ebook-faq-201105.html

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 Complaint filed with the United States Department of Education, Office for Civil

Rights by the National Federation of the Blind.

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 “Accessible” means fully and equally accessible to and independently usable

by blind individuals so that blind students and faculty members are able to acquire the same information engage in the same interactions and enjoy the same services as sighted students and faculty, with substantially equivalent ease of use.

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 “Electronic and information technology” or “EIT” includes

information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks, Automated Teller Machines (ATMs) and transaction machines, internet and intranet websites, electronic books and electronic book reading systems, search engines and databases, course management systems, classroom technology and multimedia, personal response systems (“clickers”), and office equipment such as classroom podiums, copiers and fax machines.

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 “Information technology” means any equipment or interconnected or subsystem of

equipment, that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.

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 Accessibility Audit of its EIT that will examine the accessibility and usability of

the EITs provided to students, prospective students, staff and faculty who are blind. The audit shall examine various aspects of the University’s EIT, including but not limited to, University websites, application processes, library services, course management systems, access to classroom podiums and LCD devices, course registration software, personal response systems (“clickers”) and banking arrangements, offered to students and faculty, including website and ATM access.

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 Based on results of audit, development of an EIT corrective action strategy with

time lines for completion. The strategy and time line shall be posted.

 Creation of an EIT Accessibility Policy Statement with procedures for

implementation, dissemination and training.

 Designation of University EIT Policy Monitor, with commensurate authority.

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 Procedures must require that the University purchase or recommend only EITs that

will provide the same programs, benefits and services that they do to individuals without disabilities, except that when it is technically unfeasible to do so, the procedures must require the provision of accessible alternate EITs.

 RFP language shall include that bidders meet the accessibility standards of WCAG

2.0 Level AA for web-based technology, and Section 508 and the ADA for other EIT.

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 Compliance with WCAG 2.0 Level AA for University websites. (phase-in approach)  On-going accessibility scans to ensure continued accessibility of the University’s

library website, including the capability of searching across all library collections.

 Specific requirements around the University’s Course Management Systems,

classrooms, clickers and banking as these were some of the main barriers raised by individual students and faculty. Settlement (10/11/11): http://accessibility.psu.edu/nfbpsusettlement/

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 Future procurement by FSU’s Department of Mathematics of digital technology and

digital instructional materials shall be accessible to the blind.

 FSU shall take steps necessary to ensure all accessibility barriers are removed from

specific designated math courses such that blind students can access the content of the curriculum in an equally effective and integrated manner as their non-disabled peers.

 FSU will explore the development of a campus-wide policy for procurement of

accessible instructional technology and content.

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 Posting of FSU grievance policy on various FSU websites.  Specific relief that is specific to the two plaintiffs, including monetary compensation of

$75,000 each and significant attorneys’ fees. Link to Agreement: https://nfb.org/images/nfb/documents/pdf/fsu%20settlement%20agreement.pdf Braille Monitor (1/2015): https://nfb.org/images/nfb/publications/bm/bm15/bm1501/bm150102.htm

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 Settlement Agreement incorporates very specific, step by step guidelines and

timeframes for the provision of timely and effective alternative media for required and recommended course reading assignments including course textbooks, readers, handouts, posted materials and specifically required or recommended library materials. The Agreement addresses the dissemination and training on such guidelines, tracking systems to ensure implementation and very specific reporting requirements.

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 Express provision in the Agreement regarding system for dealing with recalcitrant

faculty members regarding their obligations within these guidelines.

 DRA Fact Sheet:

http://www.dralegal.org/sites/dralegal.org/files/casefiles/factsheet_ucb.pdf

 Settlement Agreement (5/7/2013):

http://www.dralegal.org/sites/dralegal.org/files/casefiles/settlement-ucb.pdf

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 Complaint was initially filed by a blind student who was unable to participate in a

University course because of the use of an inaccessible internet-based application used for numerous aspects of coursework.

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 to electronic and information technology for persons with disabilities is based on

(1) timelines of delivery, (2) accuracy of translation, and (3) delivery in a manner and medium appropriate to the disability of the person. Such alternate[s], to be equally effective, are not required to produce the identical result or level of achievement for disabled and non-disabled persons, but must afford disabled persons equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.”

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 A change to a university program or service may constitute a fundamental

alteration if it alters the essential purpose of the program or service or any of its

  • components. In situations where a fundamental alternation can be documented,

equally effective alternative access must be provided.

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 Undue financial and administrative burdens are created when a proposed course

  • f action causes significant difficulty or expense. Because an institution must

consider all resources available when reviewing claims of undue financial and administrative burdens, the decision to invoke undue financial and administrative burdens should be carefully weighed and sufficiently documented. In situations where undue financial and administrative burdens can be documented, equally effective alternate access must still be provided.

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  • Requirement to revise policies to ensure the deployment of accessible technology

and course content in the University setting, ensure that the University’s Office of Disability Services is an effective participant in ensuring that this policy is implemented and that generally that students with disabilities are afforded equal

  • pportunities to non-disabled peers.
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 The Agreement incorporates a detailed roadmap of what must be covered by the

revised Policy, including, as a starting point, a review (self-audit) of University technology and instructional materials, procurement obligations, website compliance with WCAG 2.0 AA, to list a few.

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 Express requirement that “all instructional materials and online courses created by

a college, department, program, unit or professor must be fully accessible to individuals with disabilities at the same time they are available to any other student enrolled in that program.”

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  • The Agreement incorporates specific requirements regarding dissemination of

revised policies, including grievance policies, very specific faculty and staff training requirements and reporting obligations to the Department of Justice.

  • Plaintiff specific relief including purging of any reference to course withdrawal and

monetary award. Settlement Agreement (7/22/2013): http://www.ada.gov/louisiana-tech.htm

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Definitions:

 “Accessible” means that individuals with disabilities are able to independently

acquire the same information, engage in the same interactions, and enjoy the same services within the same timeframe as individuals without disabilities, with substantially equivalent ease of use.”

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 “Equally effective” means that the alternative format or medium communicates the

same information in as timely a fashion as does the original format or medium. Development of EIT Accessibility Policy and Procedures with substantial comment and implicit approval by the Office of Civil Rights; with broad dissemination. Posting of grievance procedure for identified accessibility barriers.

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 Procedures must require that the University purchase or recommend only EITs that

will provide the same programs, benefits and services that they do to individuals without disabilities, except when it would fundamentally alter a program or when it is technically unfeasible to do so and in such case the procedures must require the provision of accessible alternate EITs.

 RFP language shall include that bidders meet the accessibility standards of WCAG

2.0 Level AA for web-based technology, and Section 508 and the ADA for other EIT and at the University’s discretion, contract provisions in which the vendor warrants that any technology provided complies with these standards and applicable law.

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  • Appointment of EIT Coordinator.
  • Student Survey seeking input on the identification of any and all barriers

encountered.

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  • The parties anticipate that the University will identify some EIT that is old and not

currently or frequently used and that the strategy will not include provisions for going back to make such EIT accessible. If such EIT becomes currently used in a class or program, it will be made accessible in accordance with the EIT Accessibility Policy.

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  • Extensive Reporting Requirements
  • Settlement Agreement (3/10/2014):

https://nfb.org/images/nfb/documents/pdf/agreement_university_of_montana_m arch_10_2014.pdf

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NFB Press Release – Settlement (10/23/2014): https://nfb.org/national-federation- blind-and-maricopa-community-college-district-resolve-litigation (many similar provisions to the Montana Resolution Agreement)

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 Development and extensive publication of a Notice of

Nondiscrimination.

 Development of EIT Accessibility Policy to be approved

by the Office for Civil Rights.

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 Designation of EIT Accessibility Coordinator who has been given sufficient

resources and authority to coordinate and implement the EIT Policy.

 Required to complete accessibility audits at regular intervals and implement

corrective action plans. Specific requirements are incorporated into the Agreement regarding the initial audit.

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 The audit may be conducted by the University or by a third party.  There are extensive reporting requirements that extend through July 30, 2017.

OCR-Youngstown Resolution Letter (12/12/2014): http://www2.ed.gov/documents/press-releases/youngstown-state-university-letter.pdf OCR-Youngstown Agreement: http://www2.ed.gov/documents/press- releases/youngstown-state-university-agreement.pdf

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Significant focus on accessibility of websites and e-learning platforms. OCR-Cincinnati Resolution Agreement: http://www2.ed.gov/documents/press- releases/university-cincinnati-agreement.pdf OCR-Cincinnati Resolution Letter (12/12/2014): http://www2.ed.gov/documents/press- releases/university-cincinnati-letter.pdf

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 EdX was created by the Massachusetts Institute of Technology and Harvard

University as a nonprofit platform for select universities to offer MOOCs to the world. Today edX has approximately 60 universities and institutional members providing

  • ver 540 courses to over 3,000,000 learners.

 The Agreement requires that edX make significant modifications to its website,

platform and mobile applications to ensure accessibility. EdX will provide guidance and authoring tools to the entities that create and post the courses to assist them in making their content accessible and thus meeting their ADA obligations.

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 The requirements of the Agreement are broad in scope and will reach to ensure

that there is accurate captioning for the deaf, oral navigation signals for the blind and programming changes so that individuals with dexterity disabilities can navigate content without struggling with a hand-operated mouse.

 DOJ conducted a compliance review of edX under Title III of the ADA.  DOJ deems edX a place of education and a public accommodation whose

  • perations affect commerce.

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A.

Shall not discriminate on the basis of disability in the full and equal enjoyment of its goods, services, facilities, privileges, advantages, or accommodations. 42 U.S.C. § 12182(a); 28 C.F.R. § 36.201;

B.

Shall not deny individuals with disabilities the opportunity to participate in and benefit from its goods, services, facilities, privileges, advantages and

  • accommodations. 42 U.S.C. § 12182(b)(1)(A)(i); 28 C.F.R. § 36.202(a);

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C.

Shall not provide individuals with disabilities an unequal opportunity to participate in or benefit from its goods, services, facilities, privileges, advantages, and accommodations. 42 U.S.C. § 12182(b)(1)(A)(ii); 28 C.F.R. § 36.202(b);

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D.

Shall not provide individuals with disabilities with a good, service, facility, privilege, advantage, or accommodation that is different or separate from that provided to other individuals, unless such action is necessary to provide the individual or class of individuals with a good, service, facility, privilege, advantage, or accommodation, or other opportunity that is as effective as that provided to others. 42 U.S.C. § 12182(b)(1)(A)(iii); 28 C.F.R. § 36.202(c);

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E.

Shall not utilize standards, criteria, or methods of administration that have the effect of discrimination of others who are subject to common administrative control. 42 U.S.C. § 12182(b)(1)(D); 28 C.F.R. § 36.204;

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F.

Shall make reasonable modifications in policies, practices, or procedures, when the modifications are necessary to afford goods, services, facilities, privileges, advantages or accommodations to individuals with disabilities, unless edX can demonstrate that making the modifications would fundamentally alter the nature

  • f the goods, services, facilities, privileges, advantages, or accommodations. 42

U.S.C. § 12182(b)(2)(A)(ii); 28 C.F.R. § 36.302; and

Settlement Agreement (4/2/2015): http://www.justice.gov/sites/default/files/opa/press- releases/attachments/2015/04/02/edx_settlement_agreement.pdf

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G.

Shall take the necessary steps to ensure that individuals with disabilities are not excluded, denied, services, segregated, or otherwise treated differently because

  • f the absence of auxiliary aids and services, unless edX can demonstrate that

taking such steps would fundamentally alter the nature of the good, service, facility, privilege, advantage, or accommodation being offered or would result in an undue burden. 42 U.S.C. § 12182(b)(2)(A)(iii); 28 C.F.R. § 36.303.

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 Very detailed and substantive requirements, including the development of a

Website Accessibility Policy, a Website Accessibility Coordinator, Website Accessibility Consultants, Development of Guidance for Content Providers, Outside Audits with follow-up corrective action plan; Significant Reporting requirements. Settlement Agreement (4/2/2015): http://www.justice.gov/sites/default/files/opa/press- releases/attachments/2015/04/02/edx_settlement_agreement.pdf

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 On June 1, 2015 two blind students and the NFB submitted for approval by the

court a consent decree with Atlantic Cape Community College that is the most detailed and comprehensive resolution of its kind.

https://nfb.org//images/nfb/documents/pdf/accc_consent_decree.pdf

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 ACCC must adopt policies that ensure that:

  • consistent with the requirements of the ADA, opportunities afforded generally to

ACCC students are equally afforded to students with disabilities;

  • ACCC’s “Grievance Policy” applicable to disability-related issues is triggered any

time the Office of Disability Support Services has not fully resolved a student’s complaint.

  • electronic technology purchased or licensed for, or deployed to students or

prospective students is Accessible to those who are blind or visually impaired, unless its acquisition results in undue financial and administrative burdens or a fundamental alteration in a program, service or offering. ACCC shall advise vendors of its desire to procure web-based EIT that complies with the WCAG 2.0 AA standards. ACCC will request vendors to warrant in writing that any technology provided is Accessible as described in this Decree.

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Here are just some of the things that ACCC personnel must receive training on:

I.

Common assistive technologies and other auxiliary aids and services used by individuals with disabilities in interacting with computers, websites, equipment, and in learning in and outside of the classroom, including non-electronic formats;

II.

Common technological accessibility barriers encountered by individuals with disabilities, including those found on websites, in various document formats, and equipment and devices used in laboratories and classrooms;

III.

Common methods, resources, personnel and time frames used in ensuring that word processing, spreadsheet and presentation documents, converted and digital textbooks, informational images, multimedia, and course equipment and devices are Accessible;

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iv.

The means by which one creates and provides Accessible instructional materials in the classroom setting or by delivery electronically through course websites or email;

v.

An overview of accepted accessibility standards;

vi.

Consideration of selecting course texts that have accessible electronic formats, such as DAISY or ePub3.

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Within one year, ACCC shall conduct and complete a Technology Accessibility Audit of all student-facing Electronic and Information Technology, including, but not limited to ACCC’s enterprise-wide student facing systems and the public atlantic.edu web site. And here are the accessibility standards for this audit:

a.

WCAG 2.0 AA and WAI-ARIA 1.0 for web content;

b.

ATAG 2.0 for software used to create web content;

c.

UAAG 1.0 for web browsers, media players and assistive technologies;

d.

WCAG2ICT for non-web software and content;

e.

MathML 3.0 specifications for digital mathematical and scientific notation;

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f.

DAISY or ePub3 for digital publications and documents;

g.

BANA Guidelines and Standards for Tactile Graphics (2010) and Guidelines for the Production of Braille Materials through the Use of Braille Production Software (2007) for hardcopy Braille.

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Within 180 days after the completion of the Technology Accessibility Audit, ACCC shall develop a Corrective Action Strategy based on the Technology Accessibility Audit findings that will make all inaccessible EIT Accessible no later than 3 years after the completion of the Technology Accessibility Audit, except that for students with print disabilities currently enrolled at ACCC or enrolled for any semester prior to completion of the Corrective Action Strategy, ACCC will timely provide Accessible EIT or equally effective alternate access for every class in which such a student is enrolled.

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 All instructional materials, co-curricular materials, EIT, and online courses created

  • r used by an ACCC department or professor in connection with any ACCC course
  • ffering must be Accessible to individuals with disabilities at the same time they are

available to any other student enrolled in that program.

 For example, all content presented visually in a classroom, test, or homework

setting for a class that includes a student with a visual disability must be made Accessible in a nonvisual format in time to be used by that student in those same settings, including, for nontextual information, tactile graphics or high resolution magnification, as appropriate. ACCC has three years to get all the way there.

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 ACCC’s public website (atlantic.edu) and ACCC’s web interface to the student

information system (WebAdvisor), as well as any online forms, shall be made Accessible to blind and visually impaired users in accordance with WCAG 2.0 Level AA standards within 240 days of the effective date of the Decree.

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 California State Accessible Technology Initiative:

http://www.calstate.edu/accessibility/

 University of California Electronic Accessibility Policy:

http://www.ucop.edu/electronic-accessibility/initiative/policy.html

 The Ohio State University Web Accessibility Policy:

http://ada.osu.edu/resources/webaccessibilitypolicy.pdf

 Temple University policies: https://temple.edu/about/temple-university-

accessibility-statement

 University of Minnesota Accessibility Policy:

http://accessibility.umn.edu/umn-policies.html

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 On 02/11/2015, the National Association of the Deaf sued Harvard University and the

Massachusetts Institute of Technology for their failure to caption educational video.

 On 01/10/2014, Aleeha Dudley sued Miami University for its failure to provide

accessible content and technology as she sought to pursue a pre-veterinary medicine major. These failures include not only in accessible content and technology in STEM course content, but in system-wide co-curricular activity, such as the course catalog, class registration and transcript certification software. The United States Department of Justice and the National Federation of the Blind are seeking to be added as parties.

Harvard: http://creeclaw.org/wp-content/uploads/2015/02/2015-02-11-Harvard-Complaint.pdf MIT: http://creeclaw.org/wp-content/uploads/2015/02/2015-02-11-MIT-Complaint.pdf For Dudley: https://nfb.org/images/nfb/documents/pdf/miami%20teach.pdf

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