1. Electronic Curb Cuts: A new Policy with New Requirements
Colorado State University National Disability Employment Awareness Month, Fall 2016
Marla C. Roll, MS, OTR
Director, Assistive Technology Resource Center
Assistant Professor, Department of Occupational Therapy

2. Assistive Technology Resource Center (ATRC)
Our Mission: Ensuring equal access to technology and electronic information for CSU students and employees with disabilities as defined by the Americans with Disabilities Act, the ADAAA , and Sections 504 and 508 of the Rehabilitation Act

3. ATRC Services Overview
“ Assistive Technology is only as good as the content it interacts with….”
ATRC Services Overview
Provide Assistive Technology Services to employees and students with disabilities
Students are referred via RDS
Employees can self refer or learn about us through the process of working with OEO
Assist the campus with the creation of accessible course materials and accessible information.
Part of my motivation for this policy comes from the fact that my office is increasingly seeing situations where the AT cannot access the content. For example, we can provide a student that is blind screen reading software and we can be sure they know how to use it. However, if the instructor or web developer does not design the content in the correct way, then the document is inaccessible –even if the AT works perfectly! E.g pdf image files.

4. Students and Employees are Diverse
Much of the University’s instructional and business activities are conducted in whole or in part through electronic means. Are these processes and activities accessible and useable for all?
Variety of :
disabilities
learning styles
age related impairments
Technology comfort and background
We assume everyone reads and digests information in the same way. That is not the case…

5. Universal Design – Physical and Digital Worlds
ADA – precursor to the web – electronic curb cuts
The courts are extending ADA ( title II) and its reach into the digital or electronic realm.
Timely and equivalent communication
Consider accessibility as part of your work flow vs. retrofitting
Are people familiar with the ADA and its various protections? Many of us are familiar with things like curb cuts, electronic door openers, etc. In the physical realm. We are hoping that sort of cultural shift can now be applied to the digital realm – eg. Electronic curb cuts. The ADA does speak to timely and equivalent communication – but it was written prior to the internet. However, the courts are treating it as if it does extend to the digital realm. The DOJ is in the process of revising title II of the ADA to speak more directly to digital access.
The U.S. Department of Justice (DOJ) has extended the deadline for public comments regarding its proposed revision to the rules implementing Title II of the Americans with Disabilities Act (ADA). You can now submit comments until October 7, 2016.

6. Brief history of policy
CSU had an outdated web accessibility policy –
Not achievable
No awareness efforts
Great deal of legal activity in this realm.
National Federation of the Blind – has filed complaints against a handful of campuses.
National Association of the Deaf – sued Harvard and MIT – lack of captions
Higher Ed Accessibility Lawsuits, Complaints, and Settlements
Legal activity has been more in the realm of access for students than employees….

7. Who collaborated to develop a new policy
Marla Roll, Assistive Technology Resource Center
Diana Prieto, Office of Equal Opportunity
Jason Johnson, Office of General Council
Patrick Burns, VP for IT and Dean of the libraries
Robert Schur, CSU Policy office
Stakeholders:
Faculty council
RDS
OEO
Council of Deans
Graduate School
The ATRC initiated the development of a new accessibility policy ( about 4-5 years ago?)
A great deal of work went to writing a policy that was realistic and achievable.
Stakeholder feedback was sought.
Policy became live this past May. Now it is time to spread the word.

8. Accessibility of Electronic Information & Technologies
The “Policy”
CSU Policy: Accessibility of Electronic Information & Technologies
Access to information by all members of its learning community is inherent in Colorado State University’s mission as a land grant institution of higher education. In this regard, consideration must be given to the delivery and exchange of information via electronic means at Colorado State University.
Accessibility of Electronic Information & Technologies

9. Policy Purpose:
The University is committed to supporting an electronic and information technology (EIT) environment that is accessible to all, including individuals with disabilities. To this end, the University seeks to deploy EIT that has been designed, developed, or procured to be accessible to people with disabilities, including those who use assistive technologies. An accessible EIT environment generally enhances usability for everyone. By supporting EIT accessibility, the University helps ensure that a broad population is able to access, benefit from, and contribute to its programs and services.
Because our student and employee demographics are increasing becoming more diverse, we need to consider whether information is accessible and usable for all.
Typically, accessibility enhances usability. Eg. When you design a web site to have good structure and eliminate excessive content or information, it can be more used more easily by those with disabilities, can be easier to view on mobile devices and can enhance search engine optimization – your content being more easily searched and found.

10. Definitions:
Accessible refers to making EIT equally accessible to and independently usable by individuals with disabilities, so that they are able to acquire the same information, engage in the same interactions, and enjoy the same services as individuals without disabilities, with substantially equivalent ease of use, using reasonable accommodations when necessary. It does not mean that the means of access must be identical, but that an equally effective means of access is afforded.
If you can provide access to all types of users electronically then you MUST provide an equivalent format.
An example of this in the employment realm: A worker with a visual impairment could not access content in a database that was needed for a primary or essential function of the job. The employer ended up assigning a grad student to the worker to provide a reader for that database content.

11. Policy highlights:
Ensuring equally effective access as required is the responsibility of those University employees responsible for creating and publishing the content.
The University will:
(a) establish standards and guidelines for making EIT accessible;
(b) implement procurement requirements for EIT products and services;
(c) provide training, as needed, to departments, faculty and staff to enable them to utilize available software and tools to make EIT accessible;
(d) promote awareness of this policy to all members of the University community, particularly those in roles that are responsible for creating, selecting, or maintaining electronic information and technologies; and (
e) assign responsibility for accessible design of EIT to the appropriate departments and personnel.
E.g.
Pat Burns – has called together all web developers on campus to spread awareness of the policy
A web accessibility subcommittee was pulled together to help with processes for implementation
A beginning level training was provided this past week - for all campus web developers.
Today’s event is an example of trying to spread the word / increase awareness

12. Compliance with the policy
Director of the Office of Equal Opportunity - person designated to coordinate the University’s compliance with Section 504 of the Rehabilitation Act of 1973 (“Section 504”) and Title II of the Americans with Disabilities Act of 1990 (“Title II”), or the director’s designee.
ADA/Section 504 Coordinator
OEO is the office listed to assist with compliance of this policy. Eg. If a student or employee is not getting equivalent access, they can seek assistance from this office.

13. Digital accessibility in the workplace
What tools do you use in your work place that are electronic?
What content do you communicate via the web/ internet?
Brainstorm technology in the workplace
Eg. Microsoft suite of products ( word, ppt, outlook)
Databases, voip/ phone
Other?

14. Access in the workplace
How does the policy apply to the workplace or employment at CSU?
1. creation of electronic content and resources
2. procurement of EIT
3. employee with a disability- access to the tools/ information they need
Let’s break down the policy and its implications in the workplace…

15. Creation of electronic content/ information/ resources
All University web developers creating new and redesigned public-facing University web pages published on or after the effective date of this policy will refer to and strive to apply the most current version of the Web Content Accessibility Guidelines (WCAG) 2.0 AA Success Criteria, W3C Web Content Accessibility Guidelines (WCAG) 2.0).
EIT extends to web sites, course and instructional materials (Word documents, PDF documents, Power Point presentations, video, podcasts, etc.), courseware, software, other classroom technologies, content management systems, search engines and databases, registration and grades, financial and human resource management systems, telecommunications, and emerging technologies.
University departments and employees must be prepared to provide content and/or services in a suitable alternative format as required.
Can an individual outside of your department access your information in an equivalent manner?
Policy includes public facing content and controlled content. Public refers to anything accessible to the general public and controlled is content where authentication is required…
Examples of access include things like: captioning of video, is keyboard navigable, has images labeled as alt text or alt tags
If you put something up on a website that is not accessible then give people another way to access that information. E.g give them a phone number to call and a contact person to provide the same information that is provided on the web….
Can the general public access information you provide on the web? Your public facing web content?

16. What makes a web site accessible?
Web Aim:
Principles of accessible design (
Consider using WAVE – web accessibility evaluation tool
WAVE Tool (
CSU Policy: Accessibility of Electronic Information & Technologies
Show principles
Demonstrate wave tool

17. Procurement of EIT:
New EIT should be accessible upon acquisition or implementation to the greatest extent practicable.
Accessibility will be included in the procurement process:
VPAT’s – Voluntary Product Accessibility Templates
Example – CSU’s review of on-line exam proctoring tools
Accessibility resources at CSU:
Accessibility By Design: Purchasing
Put responsibility of accessible products/ technologies on the vendor
Show example of a VPAT
Mike Palmquist with CSU on-line pulled together a group to examine a standard for what technology to use for on-line proctoring
The group examined two options – for aspects including accessibility.
I am going to show you a VPAT that one of the companies provided.
This vpat demonstates that they took an accessibility review seriously.
Group decided to make both products available and let the student choose which one to use
Being used by CSU on-line, college of business and few other departments doing on-line testing/ exams

18. Steps to take in the procurement of accessible EIT:
Ask vendor to provide a VPAT
Use the list of additional questions to ask:
Accessibility By Design: Purchasing
Ask the vendor to test their product using the “Manual Accessibility Testing Checklist”
Include language about accessibility in the contract
Ask the ATRC for help!

19. Employees with disabilities access to the tools/ information they need
Are you providing employee information in an accessible manner?
Departmental policies & procedures
Search engines and Databases
Job applications
Departmental/ Unit website
Other?
Is the technology you expect an employee to use accessible?
desktop computers and software applications
financial and human resource management systems, telecommunications, and emerging technologies
Your office may have unique needs/ tools they use. Start thinking about the accessibility of those tools….

20. Awareness – help us spread the word
Share policy information with your coworkers
Be a part of a CSU community that encourages accessibility
Accessibility By Design (
CSU Web Accessibility Subcommittee – chaired by Randy Miotke/ ACNS

21. Questions? Need Assistance? Marla Roll, Director/ATRC
Allison Kidd, Accessibility Specialist/ ATRC