1. Best Practices in EIT Accessibility Ensuring Accessible Websites, Course Materials, and More
Korey Singleton
George Mason University
Bisi Ladeji Okubadejo
Ballard Spahr LLP
© All rights reserved

2. Agenda What is the issue? What is EIT “in-accessibility”?
How does this fit in with Section 504 and the ADA?
What does the government look for during an accessibility review?
How have schools addressed the issue?
The GMU model
What are some best practices?
What are recommended first steps an institution should take to address EIT accessibility?

3. Understanding Electronic and Information Technology (EIT) “In-accessibility”

4. What We Know...
Increasing numbers of students with disabilities entering IHE
Greater implementation of online/e-learning technologies in higher education classrooms (online and F2F)
Growth in distance education offerings by IHE
Growing number of legal challenges/findings against IHE by individuals with sensory impairments (visual and/or hearing loss)

5. Common Issues Inaccessible LMS’ and supplemental applications
Alternative texts (textbooks)
Document accessibility (Word, PPT, PDFs)
Captioning for videos
Inaccessible library resources (databases, search, print resources)
Additional classroom resources (e.g., iClicker, podiums)
Inaccessible university websites/web resources
ATMs
Access to auxiliary offices (financial aid, registrar)

6. What exactly does EIT Accessibility ‘look’ like?
- What is Assistive Technology?
- Demos and Examples
(Documents, Videos,Websites, and Web-based applications)

7. Types of Impairment and Assistive Technology
9/26/2017
Types of Impairment and Assistive Technology
Sensory (Loss of vision, hearing, or both)
Screen readers and refreshable braille devices for people who are bling or have other print disabilities
Open or closed captioning for people who are deaf
Learning/Cognitive
Organizations, readability
Physical
Alternatives input tools, such as speech-to-text software, for people who cannot use a computer mouse
Notes
I have listed 3 classifications here..,while there’s certainly a great deal of variation that exists under these 3 classifications, they do broadly cover much of what we are discussing here today.
When we discuss inaccessible EIT, make no mistake that 99% of the discussion (from a legal standpoint) centers around equivalent access for individuals with some degree of vision and/or hearing loss...Now, there’s only one case that I can think of which actually involved individuals with learning impairments (that was UC Berkeley and involved more timely access to printed materials in alternative formats like Braille, audio, or large print)...
So, if we move beyond thinking about the discussion in terms of disability and more about the types of assistive technology that an individual uses in order to access a computer, things start to make a bit more sense.
How instructional materials and/or our electronic resources are designed play a significant role in one’s ability to access information or participate in the programs or services that we offer...
If I am blind, I need a screen reader to access a computer and to read electronic documents
If I am deaf or hard of hearing, I need captions and transcripts for audio and video
If I have a learning impairment, I benefit from information being presented in a consistent manner and chunked so as to allow me an easier time processing that information
If I have a physical impairment which impacts my ability to use a mouse or a keyboard, I also benefit from how a document or website is structured since I too would require an alternative means for accessing a computer.

8. Anatomy of an Accessible Document
Document courtesy of Portland Community College: 0

9. Jaws Screen Reader Demo
E.g., Navigating a Word Document (a screen reader user’s perspective)
Video courtesy of High Tech Center at Taft College:

10. Before and After Demo - Websites
E.g., Improving a website using Web Content Accessibility Guidelines (WCAG) 2.0,

11. Understanding Web Accessibility
E.g., Labeling Images/Graphics
Graphics should have meaningful labels:
Ex: “Photo of Secretary of Education Arne Duncan reading to children at Central Elementary School.”
Not: “Photo”
The labels can be visible to everyone, or they can be hidden in the programming of the web page. Designer’s choice!

12. Understanding Web Accessibility
E.g., Color Contrast
Meaningful information should be conveyed through more than just color.
For example, individuals unable to identify color would not know which fields were required. A simple fix would be to add an asterisk(*) next to the required fields.

13. Understanding Web Accessibility
E.g., Keyboard Navigation
Users should be able to “tab” through the page and get to all information and functions.
Pages should not require users to manipulate a mouse for navigation.

14. Web-based Tools – Library Databases (Full-text HTML, ReadSpeaker)
Ability to translate text
Downloadable mp3 file
Also available as separate PDF
Built-in text-to-speech capability
Text Highlighting

15. Web-based Tools – Films on Demand (Captions and Transcripts)
Interactive Transcript
Captions
Searchable Video Content

16. Accessible Video Player: OzPlayer
All controls accessible via keyboard
Synchronizedaaudio description
Accurate, synchronized Captions
Interactive Video Transcript

17. Legal Requirements
- Sect. 504 and ADA

18. Legal Requirements Applicable laws:
Section 504 of the Rehabilitation Act
The Americans with Disabilities Act
Qualified individuals with disabilities must receive equal access to all of a recipient’s programs, services, and activities.

19. Legal Requirements What is “equal access”?
OCR’s guidance on emerging technology sets the standard.
“Receive all the educational benefits provided by the technology in an equally effective and equally integrated manner”
Must be able to:
Acquire the same information,
Engage in the same interactions, and
Enjoy the same services.

20. Legal Requirements Separate offline access?
“An agency with an inaccessible website may also meet its legal obligations by providing an alternative accessible way for citizens to use the programs or services, such as a staffed telephone information line. These alternatives, however, are unlikely to provide an equal degree of access in terms of hours of operation and the range of options and programs available. For example, job announcements and application forms, if posted on accessible website, would be available to people with disabilities 24 hours a day, 7 days a week.”
U.S. Department of Justice’s “Accessibility of State and Local Government Websites to People with Disabilities.” (Available at

21. Legal Requirements Regulations
Under Section 504 and Title II, recipients and public entities must ensure that qualified persons with disabilities have an equal opportunity to participate in the entities’ programs, services, and activities.

22. Legal Requirements Fundamental Alteration Defense
Covered entities do not have to do anything that would fundamentally alter the nature of the program or service they are providing.
Ex: U.S. Geological Survey’s topographic maps cannot be reduced to words to make them accessible to people who use screen readers. The very essence of their “mapness” would be destroyed in the process.

23. Legal Requirements Undue burden defense
Covered entities do not have to do anything that would impose an undue administrative or financial burden.
Ex: It might be an undue burden for a small college to try to meet a blind student’s last-minute request to provide audio-description for an online student film festival.
Note: The administrative requirements apply to “undue burden” and “fundamental alteration” here as throughout Section 504 and Title II.

24. Legal Requirements Websites v. distance learning
Distance learning: the technology supporting “live” courses should be designed to be adaptable (no need to actually provide real-time captioning, if there’s no student who needs captioning currently enrolled, but educators should be ready to do so if a student with disability joins the class).
Websites: all websites should be designed to be accessible to individuals with disabilities.
The intersection of websites and distance learning: if an archived course is available online upon demand, then it should be captioned before posting – or the educator should be ready to provide another means of effective communication.

25. Useful Guidelines
- WCAG 2.0 and Sect. 508

26. Useful Guidelines Useful guidelines for web accessibility
Web Content Accessibility Guidelines (WCAG 2.0) from the World Wide Web Consortium (W3C)
Section 508 of the Rehabilitation Act of 1973, as amended in 1998

27. Useful Guidelines WCAG 2.0 Guidelines
Web accessibility initiative of the World Wide Web Consortium “W3C”
Public/private consortium, world-wide, of academics, governments, technology industry, and user groups
Web Content Accessibility Guidelines
Optional for all web developers, including governmental entities
Especially: “Evaluating Accessibility”

28. Useful Guidelines
Section 508 Only Applies Directly to the Federal Government
Federal agencies must comply with the Section 508 standards
Others may use the Section 508 standards as guidance, but are not subject to Section 508 itself (except under some state laws)
Important: Section 508 does NOT “follow the money” like Section 504.
Section 508 Resources:

29. Governmental Review
- Compliance reviews
- Best Practices

30. Governmental Review University of Cincinnati compliance review
Youngstown State University compliance review
University of Phoenix
EdX
UC Berkeley

31. Best Practices in EITA in Higher Education
Institutions Referenced
Best Practices in EITA
CU-Boulder (2015)
Harvard/MIT (2015) – Open
EdX (2015)
Univ. of Phoenix (2015)
Miami-Ohio (2014/2015) – Open
Univ. of Cincinnati (2014)
Univ. of Montana (2014)
Youngstown State (2014)
Louisiana Tech (2013)
SCTCS (2013)
Penn St (2011)
List below based on compilation of findings from voluntary reviews/resolved/settled EITA cases
Establish/update Electronic and Information Technology (EIT) Accessibility Policy
Establish/update EITA Grievance/Remediation Process
Establish/update Procedures for Procurement
Establish EIT Accessibility Training
Establish Accessibility Web Portal/Website
Hire EIT Accessibility Staff
Establish Process for Monitoring EITA Issues
EIT Accessibility Audit...
Institution-specific resolutions (e.g., monetary compensation, department-specific applications/websites, establish non-discrimination policies)

32. Best Practices in EITA – What’s Covered?
Classroom-Specific
Campus-Specific
LMS (e.g., Moodle, Bb)
Supplemental Applications (e.g., Pearson MyLabs)
Provision of accessible/alternative text (e.g., braille, timeliness of delivery)
Document accessibility (i.e., Word, PDF)
Library databases/services
Other (e.g., iClickers, podiums, etc.)
Video accessibility (i.e., captions, video player)
Web accessibility (e.g., videos, images, documents)
Other (e.g., ATMs, kiosks, etc.)

33. - Policy & Procurement, IT Accessibility Working Group
The GMU Model
- Policy & Procurement, IT Accessibility Working Group

34. ATI Staff & Reporting Structure
University President
VP, CDE
Associate Director/ADA Coordinator, CDE
ATI Manager
IT Accessibility Coordinator
Program Support Specialist
Acc Media Coordinator
Accessible Media Specialist
Student Worker(s)
ATI operates under Compliance, Diversity, and Ethics Office
Reports up through ADA Coordinator to VP for CDE, who reports directly to University President
More information about us available at
Presentation:
ATI Office consists of an Accessible Media Coordinator, an IT Accessibility Coordinator, an Accessible Media Specialist, a Program Support Specialist, and a student worker. Those positions report to the ATI Manager, who reports to the ADA Coordinator in the Compliance, Diversity, and Ethics office. The VP for Compliance, Diversity, and Ethics reports directly to the President.

35. Accessibility@Mason: A Collaborative Partnership
CDE DS
Students w/
Disabilities
Employees w/
Disabilities
EIT Accessibility
& Compliance

36. Comparing Mason… National cases had Mason equivalents!
MyLabs and other supplemental applications
Captioning
Inaccessible websites/web-based documents
DE courses
Communication breakdowns
Purchasing/procurement issues
University’s IT infrastructure was changing
Shift away from ‘siloed’ delivery model
Enterprise systems overhauled/updated
Staffing changes

37. IT Accessibility Working Group (ITAG)
Established in/met throughout Spring 2013 and Spring 2014
Stakeholders from Library, UL, ITS, CTFE, DE, Legal, Academic Depts., and CDE
Issues and challenges centered on addressing needs of students with sensory impairments
At the time (Fall 2012), we had 81 total students with sensory impairments…included 8 incoming blind students (both grad and undergrad) and that total was almost 50/50 in terms of the number of students with vision and/or hearing loss
Why focus on sensory impairments?
Information available on our website:

38. Issues Identified by ITAG
Accessibility vs. Accommodation (Medical Model)
JIT (Adjuncts) vs. Development
Time/Staffing/Costs
Inconsistency within and across programs
Compliance/Enforcement
Costs
E-Learning Technology
Legal Issues
Non-Inclusive Practices/Awareness
Procurement
JIT vs. Development (Training resources)
Time/Staffing (What can we as an office do and what can’t we do? Similarly, what can faculty/academic units do and what can’t they do?)
Inconsistency (Champions in some areas, but not consistent across units)

39. High Priority/High Impact Recommendations
Improving Student Access in the Classroom
Provost’s Letter
Established Baseline Design Considerations (captioning, accessible document design)
Accessibility reviews for DE courses
Improved communications/collaboration
Training with Academic Units/Depts./Instructional Designers
Accessibility testing of e-learning and IT resources
Improving Web Accessibility/Procurement
ASRB Changes/Updates
Prioritization of websites for accessibility testing
Structural Improvements
Video management platform
Staffing for document accessibility support

40. HP/HI Recommendations In Practice
Communication/Collaboration
Policy Updates
For the purposes of this presentation, I have reordered the high-impact/high priority recommendations under what we specifically implemented to address communication/collaboration gaps, EIT policy updates, training resources, structural improvements, and workflow updates.

41. Improving Communication and Collaboration
Top-down Approach
Provost’s letter
Meetings with Deans/Directors
Identified Accessibility Liaisons for each College/School
Emphasis on Strategic Partnerships (Choke Points)
Joint meetings with faculty members that will have a student with a sensory impairment in their courses (ATI/Disability Services)
Collaboration with Office of Digital Learning
Accessibility training provided for Academic Units c/o Instructional Designers (IDs)
Course Portfolio Accessibility Reviews [Pilot Tested – May 2015]
Collaboration with Library (AT Labs, e-Reserves, Captioning, Procurement)
Accessibility Coordinator position established
Streaming Media Policy
“Choke Points”…in other words, we are a small office so where can we have maximum impact??

42. EIT Policy Updates
Policy 1307 – Procurement and/or Development of Administrative Systems/Applications
Updated in 2012 to reference the Architecture Standards Committee
Architectural Standards Review Board
ASRB reviews all technology purchases
Policy 1308 – Electronic and Information Technology Accessibility
Updated April 2014
Expanded definition for “electronic and information technology” and whom it applies to
Roles and Responsibilities
Findings and Recommendations from IT Accessibility Working Group
Architecture Standards Committee: The ASC is responsible for the review and approval of administrative systems/applications in advance of purchase or development, regardless of cost or purchase price.  This review will encompass the following items: a) ensure compatibility with the current suite of administrative applications, b) verify compliance with technical architecture and standards, c) verify compliance with federal, state and university policies, and d) ensure no duplication of existing administrative systems/applications exists.
Policy 1308 Definitions - Specifically took definitions language from legal settlements

43. Architecture Standards Review Board
The ASRB is under the Architecture Standards Committee (ASC) and is responsible only for approving the beginning of a given project.
Initial review includes an accessibility review by ATI and any other reviews (e.g., IT security, cloud computing, integration, etc.) necessary. At the ASRB’s discretion, changes may be required before approving a project.
Projects under the purview…include all requests for new development, installation and/or integration of applications at GMU…includes activities from internal ITS, Mason University offices, mobile apps developed by university faculty and staff, and all software produced by 3rd party vendors and consultants including pilot projects…committee will not review upgrades, bug fixes, and incremental improvements to existing programs.
ATI provides a risk analysis and recommendations for Mason purchaser.
Mason purchaser – meaning the individual/department making the purchase at GMU

44. Purchasing Contract Language
Worked with Purchasing, ITS, and Legal to include accessibility language on all purchasing contracts, including eVA purchasing agreements.
Sample purchasing agreement language -
Added protection for technology purchases that are not reviewed for accessibility.

45. Definitions Matter (Our EITA Policy)…
Lifted the definitions from Penn St. Settlement…
Accessibility –
“…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…”
Electronic and Information Technology –
“…. electronic and information technology includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems(“clickers”), and office equipment such as classroom podiums, copiers and fax machines…”
Should it be...General vs. Specific?
What technology is covered???

46. HP/HI Recommendations In Practice
Training Resource Updates
For the purposes of this presentation, I have reordered the high-impact/high priority recommendations under what we specifically implemented to address communication/collaboration gaps, EIT policy updates, training resources, structural improvements, and workflow updates.

47. Baseline Design Considerations for Accessible IT Resources
Visual:
Provide alternative text descriptions for all meaningful graphics (images, charts, graphs, SmartArt, objects)
Provide descriptions for videos where visual content is important to understanding subject matter.
Use styles in Office documents, headers and other markup for webpages
Choose applications that support keyboard navigation and are compatible with screen readers
Hearing:
Provide captions for all videos
For audio, provide transcripts
Cognitive, Neurological:
Use consistent navigation, tab order, appropriate language level
Again, we had to decide what would have maximum impact. We cannot do everything, but we can make choices that get us further down the road.

48. Guide to Creating Accessible Electronic Materials
JIT training resource provides faculty/staff with step-by-step instructions on ensuring that their electronic documents/videos are accessible to individuals with disabilities.

49. Sample #1 – GOALS Document

50. Sample #2 – ATI Created

51. Updated ATI Website Usability-group tested Easier navigation
Video training library to go along with JIT training guide
Streamlined service request process
Captioning and Audio Description
Website and Applications Testing
Reporting Issues

52. Video Training Library

53. Streamlined Services Request Process

54. HP/HI Recommendations In Practice
Structural Improvements/Workflow Updates (Captioning, Web Accessibility, Document Accessibility, Distance Education)
What the numbers show
For the purposes of this presentation, I have reordered the high-impact/high priority recommendations under what we specifically implemented to address communication/collaboration gaps, EIT policy updates, training resources, structural improvements, and workflow updates.

55. Captioning and Transcription

56. Captioning Workflow - Kaltura Pilot
ITU purchased and implemented Kaltura video management platform during Spring/Sum 2014…full implementation Fall 2014/Spring 2015
Solved a number of captioning issues
Easy process for addressing last-minute requests
Standardized video management process
RFP for captioning/transcription vendors with Kaltura partnerships
Streamlined workflows/timelines/costs
Allowed for scalability
Integrates with LMS

57. Cqptioning Specific Updates
Updated Request Form/Submission Process
Faculty/Staff have 2 ways to submit requests
Single Submission and/or Bulk Request Form
Responsibility Acknowledgement
Faculty/Staff
Videos will be used for at least one year
Transcripts/Captioned files are the property of GMU
Will receive transcript (.txt)
ATI
Transcript will be completed to at least 98% accuracy
No editing of transcripts unless egregious errors are identified
RFP/IFB for new captioning vendors
FY14 (RFP): Secured 2 vendors
FY15 (IFB): Secured 4 vendors
Disability Services (Accommodations)
Deaf/HOH Coordinator populates a semester listing of D/HOH students & their enrolled classes
Allows us to directly target faculty teaching those courses

58. What the numbers show… Completed AccMedia Requests from FY12-FY15
FY15 (so far) – 1197
Scalability and reduce per-minute costs captioning/transcription costs each year.

59. Compliance Breakdown vs. Accommodation

60. Video Breakdown per Academic Unit

61. How files are delivered

62. How files are delivered (By FY)

63. How files are delivered (FY Trendlines)

64. Who’s Using the Service?
Over 180 faculty/staff members have made requests
Top 3 Schools/Colleges/Units making requests
Volgenau School of Engineering
College of Humanities and Social Sciences
College of Science
Reasons for Request
Compliance for DE Course – 72%
Compliance for F2F Course – 0.7%
Compliance for Websites – 4.4%
Disability Accommodation – 23%
Top 3 & Reasons for Request – Allow for directed marketing approaches

65. Web and Applications Testing

66. Website and Applications Testing
University Web Audit (FY14) to prepare for new WMCS
Provided accessibility reviews, which were included in University’s web audit
Reviewed Priority 1 and Priority 2 websites (over 110 websites)
P1: Academics, Admissions, Financial Aid, Student Health, Housing, Visitors, HR
P2: Individual College and School websites
Page scans 5 levels deep, up to 100 pages
Reports provided to Web Developer
ASRB, Online request process really opened the door…

67. Website and Applications Testing (2)
University recently selected new WCMS (Drupal) to update web presence and standardize branding
Currently working with ITS and C&M on incorporating accessibility into design process
Prior to new website going live, accessibility reviews are conducted
Most websites are still in same situation that videos were in a few years ago…
A few different WCMS’ in place (CommonSpot, WordPress)
CommonSpot is being discontinued
ATI worked with ITS to review accessibility of WordPress templates that are being used
Very few developers use their own WSYIWIG (e.g., Dreamweaver, Nvu)
We are properly positioned for growth once WCMS is standardized in the next 2-3 years.

68. Website and Applications Testing Process
Web Accessibility Testing Process
Automated testing using OzArt (AccessibilityOz), WAVE (Chrome), Colour Contrast Analyzer (Paciello)
Manual testing in-house using Jaws/NVDA, keyboard navigation, other AT applications (as needed)
P1 & P2 websites reviewed quarterly
Direct requests fielded through ATI website and ASRB
ASRB, Online request process really opened the door…

69. What the numbers show… Numbers reflect growth in the following:
ASRB Reviews
Application reviews outside of the ASRB process (e.g., classroom)
Website Reviews (automated)
FY 16 a bit inflated...Spring 2016 (P3 reviews)
Website Reviews (manual)
FY14 – Increase due to University Web Audit
FY15 -

70. Document Accessibility Reviews

71. Document Accessibility Pilot (Fall 2014)
Why
Faculty members still struggling with what we are asking of them
Pilot
Working with four faculty members and 1 ID who are currently developing a DE course
Evaluated what our office could handle and what we could not
Tools used…
ABBYY Recognition Server 4.0 (PDFs and Image)
CommonLook Office (Word and PPT)
Goal
Establish a scalable process that will support faculty members who have blind students in their courses. Build toward supporting DE.

72. Document Accessibility Pilot – Results
Faculty/Staff Participants: 5
Documents Reviewed: 87
ID #1 (1 PDF, 1 Word*) = 2
Fac #1 (6 PDF) = 6
ID #2 (3 PDF, 3 Word, 1 PPT) = 7
Fac #2 (1 Word, 11 PPT) = 12
Fac #3 (17 PDF, 34 Word, 5 PPT, 2 XLS) = 58
By Document Type:
PDF (27), Word (39), PPT (16), Excel (2)
Total # of pages reviewed: 1,121
* – Word encompasses .docx, .doc, .rtf, and .txt file types., PPT encompasses .ppt and .pptx. Excel encompasses .xls and .xlsx.

73. Document Accessibility Pilot - Takeaways
What we learned?
Streamlined internal document accessibility process
Documents captured via SharePoint Doc Library
Reviewed primarily with CommonLook Office Professional
Still have some bugs to work out (e.g., alt text, final outputs, docs vs. images)
Great deal of variation in types of documents used
Better positioned to focus on accommodation at this time
Now offering service to faculty members that have a blind student enrolled in their courses.
Spring blind student, 4 courses along with orientation materials, We’ve remediated 56 documents (over 1900 pages, not including textbooks)

74. Additional Findings Helped us create a checklist:
Forced us to look deeper into Document Accessibility
Standardized Document Review Process within the office
Determined best practices
3rd–party applications: MyLabs, McGraw Hill, Cengage
Laid groundwork for DE Pilot

75. DE Course Portfolio Reviews

76. Sample – ATI Course Accessibility Checklist
Includes a review of the following areas:
Syllabus and Course Readings
Bb Learn
Word
PPT
PDF
Multimedia
Supplemental Applications

77. Sample – ATI Course Evaluation Document
Includes the following:
Priority Recommendations and Resources
Understanding the Review Process (i.e., testing tools used and process)
Findings

78. Pilot Project (Open-Call) Results cont.…
Issue Identified
Course #1
Course #2
Course #3
Course #4
Course #5
Course #6
PPT inaccessible X
Word inaccessible
Videos not captioned and/or transcribed
Video platform inaccessible
Bb Course Structure
Improper hyperlink text
Supplemental app/website
Developed DE Course Accessibility Checklist – Standardized how we reviewed courses

79. Pilot Project (DE Supported) Results cont.…
Issue Identified
Course #1
Course #2
Course #3
Course #4
Course #5
Course #6
Course #7
PPT inaccessible X
Word inaccessible
PDF Inaccessible
Videos not captioned and/or transcribed
Video platform inaccessible
Bb Course Structure
Improper hyperlink text
Supplemental app/website
Developed DE Course Accessibility Checklist – Standardized how we reviewed courses

80. Pilot Project Results Results Issues Identified!
Success!! Very well-received by faculty and DE Staff.
Asked to participate in the larger Course Portfolio Review Process
Revenue generator!
Developed DE Course Accessibility Checklist
Prioritized findings (Action Items)
Issues Identified!
Open Call vs. DE supported courses
Scalability
Developed DE Course Accessibility Checklist – Standardized how we reviewed courses

81. Evolution since Pilot Project…
We’ve been integrated into the Office of Digital Learning’s Standard Course Portfolio Review Process
We have reviewed over 50 courses since the pilot!
Improved integration!
Accessibility is now a part of the marketing process for online instruction
Inclusion in updated workflows

82. Getting Started!

83. Recommended First Steps
Identify your team
Develop/update accessibility and procurement policies
To Audit or not to Audit…
Evaluate website and EIT
Prioritize remediation
Publish a grievance process

84. Contact Information
Bisi Okubadejo,
Assistive Technology Initiative, George Mason University,