Nationwide, colleges and universities embrace the idea of a diverse student body, inclusive of students with disabilities. But creating a campus that is physically and technologically accessible to students with disabilities takes leadership, planning, and commitment. Understanding internationally accepted accessibility guidelines and federal requirements and knowing who has pioneered a truly accessible campus are key in this endeavor.
The National Federation of the Blind’s Center of Excellence in Nonvisual Access has created this online resource center to help colleges be accessible, so that your student body can be the diverse gathering of students you seek, and so that blind college students can achieve their true potential and not be limited by accessibility barriers.
This online resource includes examples of digital accessibility policies, legal requirements, and links to accessibility standards and procurement policies.
Accessible Technology Overview
Digital accessibility refers to the practice of designing electronic material so that it is usable by all people, including people with disabilities. It allows for information to be available visually, aurally, and tactilely. Most of the time, the term digital accessibility reflects the needs of those who use specially designed technology to complete tasks on a computer or mobile device. These devices and software are called access technology, and they provide for equality in education, employment, and other major life activities.
Students who are blind or have other print disabilities often use screen-reading software to verbalize or put into Braille what the sighted computer user sees. However, in order for screen-reading software to convert text into speech or Braille, the website, learning management system, or document must be created in accordance with standards and procedures that enable the software to function. If websites, learning management systems, and instructional materials are not created in accordance with accessibility standards, students who rely on the use of screen-readers will not be able to access or utilize the information they contain.
Accessibility from the Beginning
When websites, documents, learning management systems, and other applications are built accessibly from the beginning, and university procedures and procurement policies include digital accessibility requirements, students with a variety of backgrounds and abilities will have full and integrated access to all aspects of campus life. Building accessible platforms and documents from the beginning will erase the need for and cost of retroactively recreating parts of your digital content.
Standards and Guidelines
The World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 AA are widely accepted as providing for full and equal access in accordance with federal law. W3C’s Web Accessibility Initiative offers further resources including educational materials on web accessibility and working groups to improve the online experience for people with disabilities.
It is possible for all types of documents, from PowerPoints to PDF’s, to be accessible to users of access technology.
Legal Rights and Requirements
Legal Rights of Disabled Students
Under Section 504 of the Rehabilitation Act and titles II and III of the Americans with Disabilities Act, colleges and universities are obligated to provide students with disabilities equal and integrated access to higher education. Schools cannot deny students with disabilities equally effective opportunity to participate in the programs, benefits, and services they offer. This means that classrooms, cafeterias, libraries, residence halls, computer labs, and all other campus spaces, including online courses, must be accessible.
In Authors Guild v. Hathi Trust, the Second Circuit ruled that the doctrine of fair use under the Copyright Act permits anyone to make an accessible digital copy of a copyrighted print book for a person with a print disability without the permission of the copyright owner. This ruling removes the need for schools to secure from copyright owners permission prior to reproduction and redistribution, and opens up to blind students the vast quantities of information that many college libraries contain.
- Setting the Stage: Legal Precedents & Higher Education Obligations by Sharon Krevor-Weisbaum (2015)
- The National Federation of the Blind’s Self-Advocacy in Higher Education Toolkit
Federal Guidance on Equal Access to Technology in Higher Education
In 2010 and 2011, the United States Departments of Justice and Education jointly issued guidance that educational technology must be accessible to students with disabilities, and that pilot programs designed for only a small margin of the student body must likewise be accessible.
- DOE and DOJ Joint Dear Colleague Letter 2010
- DOE Dear Colleague Letter 2011
- Frequently Asked Questions on the Dear Colleague Letters
When self-advocacy and dispute resolution on campus fail to provide accommodations and equal access, blind students may be faced with no other option but to file a complaint with the United States Departments of Education or Justice, or to file a complaint in federal court. This is not an easy path for students, but it is an important one.
Key legal actions have helped to shape the definition of equal access on campus. The following complaints, agreements, and consent decrees, some with involvement of the United States Department of Education, document in very specific terms what equal access means for blind students and how it should be implemented on campus.
- Penn State University Agreement 2011
- Florida State University Settlement Agreement 2012
- University of Montana Agreement 2014
- Maricopa and Mesa Community Colleges Settlement Agreement
- University of Phoenix Settlement Agreement 2015
- DOJ agreement w/ Louisiana Tech
- Dep’t of Ed agreements with University of Cincinnati and Youngstown State
- Atlantic Cape Community College consent decree 2015
- Miami University Consent Decree 2016
Though section 504 of the Rehabilitation Act and titles II and III of the Americans with Disabilities Act protect the rights of students with disabilities to receive equal access to education, they do not provide clear guidelines for assuring these students access to the technology that has become central to the 21st-century learning experience. The AIM-HIGH (Accessible Instructional Materials in Higher Education) Act would create voluntary guidelines that would direct colleges and universities in the creation and procurement of accessible technology. Institutions of higher education that follow these guidelines would find themselves in a safe harbor, free from litigation due to inaccessibility of technology.
Planning for Digital Accessibility: a Guide to Policy and Procurement
Meeting legal obligations and providing equal access on campus is not easy. It requires time and commitment at all levels; ultimately it requires a change in culture. Adopting policies and procedures that consider accessibility can create blueprints for a truly accessible campus. Having procurement plans in place that allow only for purchasing technology that meets WCAG 2.0 AA guidelines is an easy step towards preventing disability discrimination. Many colleges and universities have already succeeded in these efforts and their policies and procedures are available for review. The following examples can help any school move towards a culture of accessibility.
Sample Policies and Guidance
- California State University’s Accessible Technology Initiative
- California University Accessible Procurement Process
- National Association of State Chief Information Officers’ Accessibility in IT Procurement; Part 1
- National Association of State Chief Information Officers’ Accessibility in IT Procurement; Part 2
- Oregon State University’s Policy on Information Technology Accessibility
- Stanford University’s Online Accessibility Policy
- Tennessee Board of Regents’ Accessibility Initiative
- The Ohio State University Web Accessibility Standards and Purchasing Procedures
- University of California’s Technology Accessibility Policy
- University of Montana’s Electronic and Information Technology Accessibility Implementation Plan
Third Party Consultants
Third party consultants can assist a college or university through the process of making their digital campus accessible.
Higher Education Accessibility Best Practices
Creating a campus whose technology is accessible takes leadership, planning, and commitment. The best path forward starts with adopting policies that require the accessibility of instructional materials and technology, followed by strong practices and procedures. By incorporating accessibility policies, practices, and procedures into their campus culture, schools including California State University, Ohio State University, and Oregon State University have proven that a digitally accessible campus is possible and can be beneficial to all students and faculty. The checklist below has been compiled from existing school guidance, settlement agreements, and consent decrees in order to help colleges and universities ensure that their campuses are digitally accessible. Can your campus answer “yes” to all of the questions posed below?
Requirements and Standards
While Section 504 of the Rehabilitation Act and Titles II and III of the Americans with Disabilities Act require colleges and universities to provide students with disabilities equal and integrated access to their programs, benefits, and services, it is the World Wide Web Consortium’s Web Content Accessibility Guidelines (WCAG) 2.0 AA, and Section 508 of the Information and Communication Technology (ICT) Final Standards and Guidelines that provide technical guidance for web-based information. WCAG 2.0 AA has been accepted throughout the web industry and is used by the US Department of Justice within settlement agreements as providing for full and equal access in accordance with federal law. Other accessibility standards include:
- UAAG 1.0 for web browsers, media players, and assistive technologies;
- ATAG 2.0 for software used to create web content;
- MathML 3.0 specifications for digital mathematical and scientific notation;
- WAI-ARIA 1.0 for web content;
- WCAG21CT for non-web software and content;
- ICT Final Standards and Guidelines. In addition to websites, the ICT Section 508 Standards apply to electronic and information technology procured by the federal government, including computer hardware and software, multimedia such as video, phone systems, and copiers. The ICT Section 255 Guidelines address access to telecommunications products and services, and apply to manufacturers of telecommunication equipment.
- DAISY for digital publications and documents;
- EPUB3 for digital publications and documents;
- EPUB Accessibility 1.0 for digital publications and documents;
- BANA Guidelines and Standards for Tactile Graphics (2010); and
- Guidelines for the Production of Braille Materials through the use of Braille Production Software (2007).
Subjects that are discussed with shared understanding are talked about and become enculturated. Does your campus use the following definitions within its policies, procedures, and daily conversation?
- Accessible: 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.
- Alternative Text: A textual description of non-text content.
- Assistive Technology: Adaptive hardware and/or software and other devices that are used to increase, maintain, or improve the functional capabilities of individuals with disabilities. Examples include text-to-speech screen access software, screen magnification software, refreshable Braille display, tactile graphics, speech input software, head pointers, and wheelchairs.
- Electronic and Information Technology (EIT): 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, the internet and intranet websites, content delivered in digital format, 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. It also includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. This term includes telecommunications products (such as telephones), information kiosks, automated teller machines (ATMs), transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.
- Instructional Support Applications: A software application, whether used in a single course, by a department, by a college or by a school, or university-wide, that a college or university makes available to students, and which is designed and dedicated to the purpose of collecting or delivering course content or assignments, or assessing student performance. An instructional support application is peripheral to a learning management system and is not necessarily used alongside a learning management system. Instructional support applications are either "non-standalone" because they contain supplementary digital content provided (either directly or through third parties) by the publishers of texts and book-length course materials, or "standalone'' because they do not contain such content. Examples of instructional support applications include: Turnitin, LearnSmart, MyStatLab, Vista Higher Learning, Sapling, and WebAssign.
- Learning Management System (LMS): A software application, whether used in a single course, by a department, by a college or by a school, or university-wide, that a college or university makes available to students and uses to plan, create, administer, document, track, report, deliver, and maintain electronic educational courses and course content and assess student performance, ncluding by enabling collaboration and communication among members of the class and between the class and instructor; by supporting the assessment of learning outcomes; and by supporting formative and summative feedback to students.
- Screen Access Software: Software programs that convert the text on a computer screen into synthesized speech and/or Braille. Examples include JAWS (Job Access with Speech), NVDA (Nonvisual Desktop Access), and Window-Eyes.
- Tactile Graphics: Objects that use raised lines and surfaces to convey non-textual information such as maps, paintings, graphs, and diagrams.
- Voluntary Product Accessibility Template (VPAT): The VPAT provides a standard format for vendors to use in reporting on the accessibility of their products.
Accessible Technology Policy
The National Federation of the Blind has found that campuses with top-down, well-defined policies regarding accessibility have greater success at implementing and maintaining an accessible campus. Sample policies from California State University, Ohio State University, and other schools are available at the National Federation of the Blind Higher Education Accessibility Online Resource Center.
- Does your campus have an accessible technology policy in place?
- Is your accessible technology policy distributed to all instructional and administrative employees, instructional and administrative contractors, and instructional and administrative volunteers who are responsible for the procurement or provision of technology?
- Is it posted publically on your school’s website and intranet?
- Does your policy incorporate or refer to procedures for providing students with disabilities with timely access to accessible course materials in electronic and hard copy formats?
- Does your policy designate an Accessibility Coordinator with campus-wide oversight? Does the Accessibility Coordinator report to the President or a member of the President’s executive team?
- Does your policy require the Accessibility Coordinator to be knowledgeable about the accessibility and usability of web content and technology (including technology commonly used in the classroom and laboratories), testing and evaluation of the accessibility of web and other technologies, and the accessibility standards listed above in Requirements and Standards? Does your policy also require the Accessibility Coordinator to be familiar with accessible document development and remediation, and the appropriate provision of non-electronic or non-digital formats, such as hard copy Braille, tactile graphics, and sign language interpreters?
- Does your policy permit reasonable modifications to policies, practices, and procedures, such as procuring technologies outside of general policies and making reasonable security exceptions for assistive technologies?
- Are staff and faculty responsible for knowing and adhering to these policies?
Procurement of Technology
Exemplar procurement language from Ohio State University and other schools is available at the National Federation of the Blind Higher Education Accessibility Online Resource Center.
- Does your campus have centralized procurement language that advises vendors of your institution’s requirement to procure EIT that complies with the applicable accessibility standards listed above in Requirements and Standards?
- Do your procurement procedures require vendors to warrant in writing that any technology provided is accessible?
- Do your procurement procedures require vendors to provide results of accessibility testing and written documentation verifying accessibility, to promptly respond to and resolve accessibility complaints, and to indemnify and hold the institution harmless in the event of claims arising from inaccessibility?
- Do your procurement procedures require vendors to provide log-in credentials to permit independent testing of EIT (such as learning management systems and instructional support applications) through automated, expert, and user-testing? Does your independent testing of EIT permit in-house staff or third party consultants to verify the claims of the VPAT and any available accessibility evaluations to determine the product’s conformance with WCAG 2.0 AA and its usability by students with disabilities?
- Does your school have a grievance procedure for disability discrimination complaints? Is the procedure posted in an accessible format and in an easy-to-find location on your school’s website?
- Does your school’s grievance procedure identify who is responsible for conducting grievance investigations and does it include a timeline within which investigations and determinations must be completed?
- Does it include a fair and timely appeal process?
- If the grievance procedure requires students to complete a complaint form, has the form been tested for accessibility when used with screen access software?
Accessible Technology Training
- Does your campus have an accessible technology training program that addresses the requirements of the ADA, available resources for students and instructors on disability-related matters, and grievance procedures?
- Is accessible technology training provided to:
- Employees responsible for writing or publishing web content;
- An academic technology specialist from each of your institution’s colleges, schools, and libraries;
- Employees who provide support for educational technology, including LMSs, equipment, software, and applications;
- Employees responsible for procurement of educational or digital technology;
- Employees responsible for converting hard copy materials into electronic and alternate formats;
- Professional-level employees in your institution’s disability support services office;
- Employees responsible for ADA compliance;
- Faculty and their administrative assistants;
- Teaching assistants and student assistants for any course in which at least one student is enrolled who is registered with the disability support services office; and
- Student assistants hired or retained to accommodate students?
- As appropriate, does the accessible technology training include the following topics?
- Your institution’s accessible technology policy;
- Common assistive technologies and other aids and services used by individuals with disabilities to interact with computers, websites, equipment, and in learning inside and outside of the classroom;
- Common technological accessibility barriers encountered by individuals with disabilities;
- Common methods, resources, personnel, and time frames used to ensure that instructional materials, text books, and course equipment and devices are accessible;
- Means by which one creates and provides accessible instructional materials in the classroom setting or by electronic delivery through course websites or email;
- An overview of accepted accessibility standards;
- Consideration of selecting course texts that have accessible electronic formats;
- The process for requesting and receiving accommodations; and
- Procedures on reporting to the disability support services office if a student reports to faculty or teaching assistants the existence of inaccessible course materials or technologies
- Does your institution provide refresher accessible technology training on an annual basis?
- Does your campus new student orientation include a presentation on the resources available to students with disabilities, including:
- The functions of the institution’s ADA coordinator and disability support services office;
- An overview of the accessible technology policy;
- The process for requesting accommodations; and
- The grievance policy and process pertaining to disability-related issues?
Technology Accessibility Audit
- Has your campus completed a technology accessibility audit of all student-facing and faculty/staff-facing electronic and information technology (including enterprise-wide student-facing and faculty/staff-facing systems), and your school’s public website to determine compliance with the following standards?
- WCAG 2.0 AA and WAI-ARIA for web content;
- ATAG 2.0 for software used to create web content;
- UAAG 1.0 for web browsers, media players, and assistive technologies;
- WCAG21CT for non-web software and content;
- MathML 3.0 specifications for digital mathematical and scientific notation;
- ICT Final Standards and Guidelines. In addition to websites, the ICT Section 508 Standards apply to electronic and information technology procured by the federal government, including computer hardware and software, websites, multimedia such as video, phone systems, and copiers. The ICT Section 255 Guidelines address access to telecommunications products and services, and apply to manufacturers of telecommunication equipment.
- DAISY or EPUB3 for digital publications and documents;
- EPUB Accessibility 1.0 for digital publications and documents;
- 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 hard copy Braille.
- Have these findings been used to develop an Accessibility Action Plan with a timeline for accessibility remediation? Has this plan been communicated to all staff and faculty?
- Is the Accessibility Action Plan available in an accessible format on your institution’s public website?
- Does the Accessibility Action Plan designate an Accessibility Coordinator responsible for the plan’s implementation?
- Does your campus provide resources for staff and faculty for making accessible instructional materials, co-curricular materials, EIT, and online courses? Have these resources been publicized to all staff and faculty, along with your school’s policy that all materials and content be fully and equally accessible to individuals with disabilities? Suggested resources are available at the National Federation of the Blind Higher Education Accessibility Online Resource Center.
- Does your disability support services office meet each semester with every student registered with that office who identifies as having a disability for which assistive technologies or the provision of instructional materials in alternate formats is necessary, and with his or her instructors to determine what alternate format the student needs for his or her instructional materials, what assistive technologies the student uses or needs, and what formats will work with the student’s assistive technologies?
- Does your institution make print textbooks available in a timely manner in the alternate accessible format requested by a student with a print disability, such as in Braille or an electronic format that complies with the EPUB3 standard, together with tactile graphics, description, or high resolution magnification?
- Does the process for requesting an alternate format for a textbook include an accessible form that can be independently completed by a blind student?
- Does your campus take care to not condition the provision of accessible information upon early registration?
- Does your disability support services office verify accessibility before providing an electronic textbook to a student?
- Does your campus ensure that tactile graphics comply with the Braille Authority of North America's "Guidelines and Standards for Tactile Graphics" and are proofed by a qualified proofreader?
- Are your institution’s public website, web interface to any student or staff information system, as well as web applications and web content accessible in accordance with WCAG 2.0 Level AA standards?
- Are third-party content, websites, forms, and applications used by your institution to complete critical or important transactions (e.g., campus housing, campus dining, class registration, payment of bills, requests for transcripts, completion of required training) accessible in accordance with WCAG 2.0 AA?
- Has your campus implemented processes to:
- train all new content creators to create content and provide reference materials accessibly?
- periodically monitor and remediate any barriers on any subsequently added web pages or content?
- provide a prominent link on its website to an accessible form reporting any barriers for remediation?
- conduct user testing to identify accessibility barriers to any major revisions of its website to ensure compliance prior to implementation of such revisions?
Contact the NFB
The National Federation of the Blind knows that blindness does not define blind students or their futures. We work to raise expectations and to remove obstacles between blind students are their dreams. The NFB’s Center of Excellence in Nonvisual Access serves to share the considerable knowledge that the NFB and its partners have of web accessibility and access technology in order to bring about greater accessibility in government, education, business, and to promote best practices nationally.
Contact us for more information:
National Federation of the Blind
Center of Excellence in Nonvisual Access
200 East Wells Street at Jernigan Place
Baltimore, Maryland 21230
410-695-9314, option 5
Email: [email protected]
As a reminder of why accessibility on campus is necessary, the following students’ stories attest to how access barriers can greatly impact, if not derail, college experiences and ultimately career successes. These are just a sample of the students who are affected by inaccessibility on campus.
A few semesters ago, I took a statistics class which had a significant online component. All homework was completed online, and there were myriad study tools which could be accessed electronically. I knew the class was going to be a challenge for me, math is not my strongest subject, but was looking forward to utilizing the online resources. Much to my disappointment, they were completely inaccessible to me. I was able to complete the assignments with the help of a sighted reader, but could not access the study material at my leisure as my sighted peers could. I don’t mind struggling through an inherently challenging class, but when that struggle is compounded by inaccessible material, it is discouraging indeed. Conversely, when instructional materials are accessible, it opens up a world of opportunity to blind students. I am currently enrolled in a Master’s program through Colorado State University’s online campus. All required instructional material is accessible to me, and I am able to study at my leisure, hold down a job in my home town and be there for my son whenever he needs me. — Angela, California
My most recent encounter with inaccessible educational technology occurred when I took an introductory microeconomics course last semester. The weekly problem sets for the class were to be completed on a website called Aplia, and I discovered that assignments on this site cannot be read at all using screen reading software. I was therefore unable to complete these assignments independently, and had to rely on a human reader to recite the questions and enter my responses. Although I was able to complete the homework with the help of this assistant, I believe that not being able to do so on my own had a negative impact on my learning experience and potential. I often felt rushed while answering questions with a reader present, not wanting to take too much of their time. I also could not simply go back to the problem sets and study them at any time for an exam, as my fellow students were able to do ... It is critical for students with print disabilities to have the same opportunities to succeed academically and achieve their goals as non-disabled students. Currently, inaccessible educational technology is so pervasive that this kind of equality is not entirely possible, as so many academic resources are not available to us. — Kyra, California
I have had routine difficulties independently completing such necessary tasks as registering for classes, accessing online readings, filling out course evaluations, viewing my grades, communicating with various campus offices, reachable only through inaccessible online forms, etc., etc. (the list could go on for pages). I was once, as an undergraduate, initially informed I would not be eligible for a position as a tutor at my school's writing center solely, I was told, because the web interface the center used had not been made accessible. — Lucy, California
I have found many of my electronic readings to be poorly tagged in .pdf files that a text to speech screen-reading program cannot decipher. Instead of having access equal to that of my peers to course readings, the disability student services office has to convert the documents into text files and I have to wait to have access to the materials. This system is inefficient and it leaves me at a disadvantage to my classmates. This is one of many examples of access barriers I have encountered due to inaccessible technology. And stories like mine are all too common among blind college and graduate students. Why are blind students not receiving equal access to all aspects of education? It isn’t because accessibility is difficult or expensive to achieve. And it isn’t because universities are maliciously discriminating against blind students. It is simply because schools, for the most part, don’t really understand what accessibility looks like. And, therefore, the schools do not know what accessibility features to demand from those who create the technologies they purchase and use. — Sean, Massachusetts
Throughout my time in college, technology has begun to play a more significant role in higher education. Now, some of the classes I am required to take for my major are mixed medium classes, meaning we meet once a week in a physical classroom and do the rest of the work online. This usually involves listening to lectures, or watching videos recorded by our teachers. Unfortunately, the video/audio player adopted by my university is inaccessible to me as a blind student. When I click on the link to access my lecture, I am taken to a page that my screen reader describes as blank. I cannot access the buttons to play the media file, let alone jump around in it to access different parts of the material. This means that I am at a severe disadvantage in comparison to my sighted classmates. — Karen, Nebraska
I didn’t even take my math placement exam because it was not accessible, so I was forced to start with college algebra rather than potentially calculus. Therefore, majors with more than that as a requirement for me went right out of the window because I could not conceive success without braille or accessible web tools that described the content. — Cindy, Washington
The problem is not the fact that I am blind.The problem is the fact that inaccessible technology is woven into the fabric of the collegiate academic experience at many institutions.Nobody wants the technology to be inaccessible, but no one has guidelines on how to ensure that I can be welcome in higher education. Well-meaning institutions can and do go awry without these guidelines. — Justin, Louisiana
When you think of your college days, a variety of thoughts probably come to mind: dining hall food, late night studying, having fun with your friends, cramming for tests, and participating in activities that you found interesting. Many blind students have these memories as well, but they are tarnished with the memories of figuring out how to navigate a website that is not compatible with a screen reader, the anxiety of falling behind in class because reading materials are inaccessible, and the embarrassment of asking a friend or classmate for assistance navigating these issues.Think of how your recollection would change if you had to tackle these challenges on top of the daily stresses that every college student faces (such as how to pay for school, develop study techniques, maintain good relationships with friends etc.).I'm not saying that college is unbearable for blind students, but I am saying that we are currently at a disadvantage in the classroom. — Lizzy, Pennsylvania