This publication shares the proceedings of Washington State Accessible IT Capacity Building Institute on Policy #188, which was held in Seattle, Washington on November 29 – 30, 2016. Attendees included individuals identified by their institution as the Policy #188 IT accessibility coordinator from higher education institutions across Washington State. Policy #188 serves to ensure that IT procured, developed, and used by state agencies, including public colleges and universities, is accessible to and usable by individuals with disabilities.
These proceedings may be useful for people who
This event was sponsored by UW Accessible Technology Services (ATS) at the University of Washington (UW), a UW-IT (University of Washington Information Technology) unit that directs both the Access Technology and DO-IT (Disabilities, Opportunities, Internetworking, and Technology) Centers. The meeting was facilitated by Dr. Sheryl Burgstahler, the director of ATS. ATS’s two centers are dedicated to empowering people with disabilities through technology and education. They promote awareness and accessibility to maximize the potential of individuals with disabilities and make our communities more vibrant, diverse, and inclusive.
The DO-IT Center strives to
The Access Technology Center (ATC) focuses on ensuring UW students, faculty, and staff with disabilities have the same access to technology—including computers, software, and special equipment—as other students, faculty, and staff. ATC staff help individuals select and use assistive technology and supports a showroom with numerous products:
The show room includes a collection of accessible science equipment such as automatic stirrers, tactile measuring devices, and talking calculators. The ATC provides braille embossing and tactile graphics for the UW community.
ATC staff promote the development and use of accessible technology products by
The Washington State Accessible IT Capacity Building Institute on Policy #188 provided a forum for prioritizing work to help every institution meet the two deadlines presented in the Policy.
By December 31, 2016, agencies must identify an information technology accessibility coordinator to be the key contact regarding the agency’s information technology accessibility plan and to support complaint resolution, and develop policy and processes to support and ensure compliance with this policy and associated standard.
By March 31, 2017 the initial agency plan must be developed and posted.
The CBI included presentations and discussions. In small working groups, participants responded to the following questions:
In this CBI
CBI participants shared their diverse perspectives and expertise. The agenda for the CBI and summaries of the presentations are provided on the following pages.
8:00 – 9:00 am
Breakfast and Networking
9:00 – 9:30
Welcome, Introductions
Meeting Goal: Improve the accessibility of IT developed, procured, & used by public postsecondary institutions in Washington State
Objectives:
9:30 – 10:30
Overview of Legal Foundation for Accessible IT
Definition of “Accessible”
Lessons Learned from Resolutions of Legal Challenges Regarding the Accessibility of IT at Other Schools
Meeting Facilitator: Sheryl Burgstahler, Policy #188 Coordinator, University of Washington
10:45 – 12
Overview of State Policy #188 Requirements
Sheryl Burgstahler, Q&A about Policy #188: Engagement with Ryan Leisinger, WATech
12:00 – 12:45
Lunch & Discussion: What are questions/concerns you have about implementing Policy #188 on your campus?
Write responses on post-its & place on poster sheets
1:00 – 1:30
Welcome from Aaron Powell, UW’s Interim Vice President for UW-IT & CIO
1:30 – 2:15
Small Group Discussions: What are key steps you are taking or plan to take to implement Policy #188?
Write responses on flip charts & handouts
2:30 – 3:00
Report out From Small Group Discussions
3:00 – 4:00
Small Group Discussions: What are the campus leaders/units that should be involved in complying with Policy #188, what roles do/will they play, & what processes are in place or need to be developed?
Write responses on flip charts & handouts
4:00 – 5:00
Report out From Small Group Discussions, Further Discussion, & Plans for Tomorrow
8:00 – 9:00 am
Breakfast & Networking
9:00 – 9:45
Feedback from Yesterday & Discussion of How Campuses Can Collaborate in Meeting Policy #188 Requirements
9:45 – 10:30
Develop Individual Campus Plans in Groups or as Individuals
10:45 – 12
Report-out From Campus Plan Development Activity
Resources available, resources desired, and ways to continue to work together
12:00 –
Lunch & Continued Discussion
Presenter: Sheryl Burgstahler, University of Washington, with input from attendees
Educational institutions across the nation are under scrutiny for failing to offer accessible classes and online resources. Many civil rights complaints have been made because IT is not accessible to individuals with disabilities—including uncaptioned videos, unreadable PDFs, and inaccessible websites and information kiosks. The legal basis for these lawsuits is Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act (ADA) of 1990 and it’s 2008 amendments, and other state and local laws. Policy #188 is meant to help us comply with these laws and collaborate in our efforts to ensure that our IT is accessible to all faculty, students, staff, and visitors.
According to the U.S. Department of Justice and the Office of Civil Rights of the U.S. Department of Education, “accessible” means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner. On our campuses, everyone’s ability to see, hear, learn, walk, etc. falls somewhere on a continuum. Regardless of where that is, we want to ensure that they have access to the IT we procure, develop and use.
There are two approaches for making our campuses accessible: accommodations and universal design. Accommodations are reactive and allow us to fix a product or environment to be accessible to an individual who finds it inaccessible (e.g., captioning a video when a student with a hearing impairment requests it). Universal design is the proactive design of creating all aspects as accessible as possible before offering services and resources to others. A building that is technically accessible would have a separate ramp for people with wheelchairs, while a building that is universally designed would have one entrance that is accessible for all.
To make IT accessible, software and websites have to be designed with disabilities and assistive technology in mind. Some assistive technology emulates a keyboard but not a mouse, tabs from link to link, reads from heading to heading, and has issues with image and audio content. This means all information technology needs to be created with keyboard-only functionality, alternative text, descriptive links, structured hierarchical headings, video captions, and transcribed audio.
From other lawsuits and accessibility cases, we have learned the importance of gaining support from key leaders, building on existing roles and processes, developing partnerships with vendors, applying top down and bottom up approaches, sharing consistent messages on accessibility, securing a leadership commitment, leveraging third parties for consultation and audits, adopting a reporting process, engaging with community members with disabilities, and ensuring wide publication of accessibility issues and solutions.
The University of Washington (UW) utilizes these resolutions, the 2015 EDUCAUSE IT Accessibility Risk Statements and Evidence report, and Policy #188 to guide its steps towards improved IT accessibility. UW promotes accessibility within an inclusive campus culture. Other tasks IT departments can take on include the following:
Learn more about what the UW is doing, see other institution’s civil rights complaints resolutions, and find more resources at the UW Accessibility page.
Presenter: Sheryl Burgstahler, University of Washington
WA Policy #188 establishes the expectation for state agencies that people with disabilities have access to and use of information and data and be provided access to the same services and content that is available to people without disabilities. By December 31, 2016, agencies must identify an IT accessibility coordinator as the key contact regarding the agency’s information technology accessibility plan, as well as the first line of support for complaint resolution. Agencies must also develop policies and processes to ensure compliance with Policy #188; although agencies might currently have goals and accessibility statements, these plans should be refreshed and tailored to ensure Policy #188 compliance. By March 31, a compliance plan should be put in place to describe how an institution will ensure new IT is accessible and how existing IT will be made accessible. The plan will contain a list of prioritized non-accessible IT, recommended alternatives for access to these technologies, and actions to be taken to make these technologies accessible.
For each instance of noncompliance of a technology, a waiver must be requested by the state CIO with a corrective action plan for each area of noncompliance and identification of the barriers and compromised functionality in relation to this noncompliance.
Attendees were invited to ask questions about Policy #188. Below is a summary of the responses.
The “technical” aspect specifically looks at some systems set in place by the state government, where there are older interfaces that cannot be made fully accessible. The “legal” aspect was added so that accessibility couldn’t be used as a loophole to access protected data.
That date will encourage us to plan together instead of procrastinating. These requirements are meant to showcase how each institution is moving forward with accessibility.
Research is not included in the scope of the policy, but it is recommended that accessibility issues be addressed since both the ADA and Section 504 cover research applications.
We hope to change the culture to include accessibility in Washington State. It doesn’t necessarily matter how many people are going to use a system or product, except possibly for prioritization. All IT should eventually be made as accessible as possible. The Office of the Chief Information Officer (OCIO) will not be auditing to determine if all waivers are submitted.
Yes, on the Office of the CIO website.
I would prefer that waivers be used to test products for accessibility and to find out what isn’t accessible. If you know a vendor is working on something, put that in a waiver. The waiver should include a plan for improving accessibility. The waiver is not a punishment, but rather an opportunity to discuss these accessibility options.
We are writing a statement to be used when communicating with vendors about accessibility. If something cannot be made accessible right away, look at making accommodations for the current product, then ask the vendor to provide a more accessible product by a specific deadline.
All software purchasers should be included in the policy for buying accessible software. If a purchaser doesn’t realize the ramifications for inaccessibility, or even how to tell if something is inaccessible, they won’t change their approach.
There are some lists out there, but there is certainly room for a bigger database or shared resource including the accessibility information of all software products.
From a legal standpoint, we should start with technology for which there have been accessibility complaints. Next we should focus on human resources software and software accessed by the public. The initial plan should cover all current high priority products, but also be a working document that can be expanded. You should also look for low-hanging fruit. It’s easier to train or contract for others to create accessible websites, PDFs, and videos, so that may be a good place to start as well.
Policy #188 only looks at software. However, the ADA covers hardware and other IT and campus accessibility.
The outcome is that your school won’t meet a state standard, which could have repercussions.
It’s rare that an application fully complies with Web Content Accessibility Guidelines (WCAG) 2.0 guidelines. Accessibility is not a switch that can just be turned on and off. Accessibility is a spectrum, with software lying somewhere on that spectrum.
Policy #188 will change the culture with respect to IT accessibility. Companies put out new updates and software on a regular basis. They are constantly taking feedback about technology and making changes in new updates. This is a good model to follow, with accessibility in a constant conversation between the user and the producer. We want to constantly be making products more usable. There will always be conflicts between accessibility, availability, and quick turn around.
And remember—it isn’t just you in this room taking this on. There are allies across your institution. There are allies across the nation. And we can all collaborate, find resources, and work together to make all of our tools, equipment, and spaces as accessible as possible.
The following are examples of responses given to discussion questions.
Some questions and concerns were discussed during the CBI and submitted on handouts. Some are listed below.
Stakeholder groups represented in the CBI included
The following individuals participated in the CBI.
Abbay, Lynne
Olympic College
Ales, Maria
Seattle Central College
Bronsema, Max
Western Washington University
Brown, Kayla
University of Washington
Burgstahler, Sheryl
University of Washington
Campbell, Ian
University of Washington
Chambers, Kathleen
North Seattle College
Chan, Brian
Green River College
Comden, Dan
University of Washington
Corey, Dana
Pierce College
Corigliano, Paul
Renton Technical College
Crawford, Lyla
University of Washington
Fraser, Scott
Washington State University
Gerard, Carly
Gonzaga University
Gilbertson, Torey
University of Washington
Golden, Anna Marie
University of Washington
Greear, Krista
University of WA
Hansen, Joyce
Seattle College District
Hartman, Robert
Bellingham Technical College
Hayman, Doug
University of Washington
Heiser, Andy
Skagit Valley College
Hodgen, Ken
Walla Walla Community College
Hsu, Raymond
University of Washington
Irish, Bridget
The Evergreen State College
Krauss, Clay
Tacoma Community College
Larreau, Tim
Washington State University Tri-Cities
Lattin, Zach
Clark College
Leisinger, Ryan
WATech
Madison, Rose
Everett Community College
Miche, Yanko
Eastern Washington University
Naf, Ward
Whatcom Community College
Park, Karen J.
Seattle Pacific University
Peoples, Vanessa
Community Colleges of Spokane
Pow, Patrick
University of Washington Tacoma
Powell, Aaron
University of Washington
Rangin, Hadi
University of Washington
Rasul, Kamran
Columbia Basin College
Rohr, Katy
Centralia College
Rover, Amy
Shoreline Community College
Seda, Jeremy P.
Big Bend Community College
Smith, Eva
Edmonds Community College
Steele, Wendy
Washington State University Global Campus (Online Education)
Taylor, Michael
Clover Park Technical College
Taylor, Patrick
Bates Technical College
Thompson, Ana
University of Washington Bothell
Thompson, Jess
WA State Board for Community & Technical Colleges
Thompson, Terrill
University of Washington
Tucker, Jeannie
Wenatchee Valley College
Wegner, Mary Kay
Bellevue College
Wenke, Richard
Grays Harbor College
Winkelbauer, Nick
University of Washington
UW Accessible Technology Services engages stakeholders within Communities of Practice (CoPs). CoP members share perspectives and expertise and identify practices that promote the participation of people with disabilities in postsecondary education.
This CoP is populated with disability services and IT professionals interested in increasing the accessibility of IT in postsecondary education, particularly in Washington State. Participants
This CoP is comprised of individuals interested in exploring universal design (UD) and its applications in higher education. Participants on this CoP discuss
Distance learning program administrators, instructors, and support staff use the Accessible Distance Learning CoP to increase their knowledge about disabilities and make changes in distance learning that lead to more inclusive practices. Members discuss
You and your colleagues can join the CoP by sending the following information to doit@uw.edu:
Visit online for more information about other CoPs.
You can find the full text for Policy #188, information about waivers, and the minimum accessibility standard by visiting these websites:
The UW’s Accessible Technology website includes a variety of resources:
The DO-IT (Disabilities, Opportunities, Internetworking, and Technology) website contains the following:
DO-IT maintains a searchable database of frequently asked questions, case studies, and promising practices related to how educators and employers can fully include students with disabilities. The Knowledge Base is an excellent resource for ideas that can be implemented in programs in order to better serve students with disabilities. In particular, the promising practices articles serve to spread the word about practices that show evidence of improving the participation of people with disabilities in postsecondary education.
Examples of Knowledge Base questions include the following:
Individuals and organizations are encouraged to propose questions and answers, case studies, and promising practices for the Knowledge Base. Contributions and suggestions can be sent to doit@uw.edu.
For more information on making your campus technology accessible and to learn more about accessible learning or universal design, review the following websites and brochures:
Conferences can be a great way to share resources, collaborate, and come up with new ideas. Consider attending the following:
The Washington State Accessible IT Capacity Building Institute on Policy #188 was funded by Access Technology Services at the University of Washington. Any opinions, findings, and conclusions or recommendations expressed in this material are those of the CBI presenters, attendees, and publication authors and do not necessarily reflect the views of the University of Washington.
Accessible Technology Services
University of Washington
Box 354842
Seattle, WA 98195-4842
www.washington.edu/accessibility/
www.washington.edu/doit/
206-685-3648 (voice/TTY)
888-972-3648 (toll free voice/TTY)
206-221-4171 (FAX)
509-328-9331 (voice/TTY) Spokane
© 2016 University of Washington. Permission is granted to copy this publication for educational, noncommercial purposes, provided the source is acknowledged.