Accessibility compliance and sustainable business processes for web, instructional materials, and procurement

Presenters

  • Cheryl Pruitt (CP), Director, Accessible Technology, CSU Office of the Chancellor
  • Sue Cullen (SC), Assistant Director, CSU Office off the Chancellor
  • Leslie Kennedy (LK), Director, Academic Technology Solutions, CSU Office of the Chancellor

When you think of Accessibility Compliance and Sustainable Business Processes, What comes to Mind?

  • It’s difficult!
  • Voting
  • Reading lunch menu
  • Viewing sports events
  • Frankly anything!

Does this affect many people? YES

  • 2010 census report, about 56.7 million people – 19 percent of the population – had a disability
  • % of undergrads who reported having a disability was 19.4 percent in 15/16
  • 26 percent of undergrads who were vets reported having a disability
  • CSU students with disabilities self identified and validated: 2016 16,429 verified disability!

Accessibility is a Civil Right

  • Rehabilitation Act of 1973, section 504 and 508
  • Americans with Disabilities Act (ADA) 1990
  • Campus violations can result in charges of discriminatory practices by the Office of Civil Rights (OCR)
  • Get buy-in from faculty, staff, and administration on the importance of accessibility as a civil right

Neglecting Accessibility…A Closer Look

  • OCR complaints: student and outsider complaints
  • Lawsuits: National Federation of the Blind, National Association of the Deaf

Sustainable Business Processes to Support

  • Civil rights
  • Students academic pursuits (curriculum, extracurricular)
  • Faculty, staff, administrators and the public
  • Universal Design approach to support goals of inclusion and Civil Rights

ATI Supporting Civil Rights

  • Policy: collaborative development, report development, assessment data – ATI Annual reports, training ATI maturity model
  • Generic sustainable business process development: 3 COPs, Working groups, accessible technology network, proof of concepts, campus exemplar examples shared in COP groups, Sharepoint website.
  • Governed through EO 1111. “It is CSU policy to ensure that individuals with disabilities shall have ewqual access to and the opportunity to participate in CSU programs, activities and services.”

CSU ATI Framework: Policy, 3 priority areas, Strategies

  • CMM: 25 goals and 150+ success indicators
  • Continuous business process improvement with strong executive support
  • Make a campus plan > Work the campus plan > Measure Progress
  • 3 high level priority areas: Procurement, Instructional Materials, Web

ATI Steering Committee

  • Provides support, resources, guides implementation, approves plan and ATI reports.
  • ATI steering committee chair, PM, VPs, Academic Senate, DSS, ADA compliance officer

Determine Impact: ATI Prioritization Framework 5-Step Approach

  1. Assess risk factors (impact, likelihood of significant barriers, probability: likelihood of consequences)
  2. Assign risk level (High, Medium, Low)
  3. Determine campus capacity (What resources needed?)
  4. Set priority level (to determine course of action consider the risk level to campus)
  5. Take action (document decisions, acquire resources needed)

Q: where do success indicators come from? Who created them? CP: no blueprint existed when we started out. We adopted a capability maturity model because of the scale/depth/breadth of scope. Our success criteria ended up appearing in some of our OCR complaints.

Q: is there any data showing student success based on any of this? CP: users are not self-identifying, so it’s tough. We DO have data on students served with accommodations.

Generic sustainable business process development

  • Goals and success indicators provide a roadmap for moving ATI forward: applying status levels, creating generic business processes
  • ATI Prioritization Framework: impact and probability – risk assessment
  • Roles & responsibilities: president appoint ATI sponsor; steering committee

Generic 4 Step Process

  1. Procurement: templates, roles & responsibilities, vendor requirements
  2. VPAT review process and training
  3. Estimated effort to implement process; individual campus: procurement process training and VPAT training
  4. CO procurement product reviews RFPs, MEAs, etc.: Vendor and RFP requirements, document reviews, vendor consultation, vendor demo

ATI Services Network

  • Processes design and template development
  • Library database accessibility documentation critical review
  • Web support for systemwide automated evaluation tool: systemwide shared checkpoints; training

Web

  • Automated and manual systemwide web training: video training & participation assessment
  • For all members of the campus community: intro to accessibility
  • Web Developers: HTML5 accessibility; JS accessibility; Compliance Sheriff Product training
  • Web content creators and web developers
  • Manual evaluation worksheet template and training resource

Instructional Materials

  • AIMHub services
  • Captioning roles & responsibilities 3rd party contract (CaptionSync): training, prioritization, custom video training webinars
  • CommonLook Pilot: tools & remediation services contract
  • Library database reviews
  • Faculty Information Home: navigation of online materials, how-to materials, administrative and planning considerations, shared student work, resources

Cheryl reviewed the procurement working group’s 4-step process development.

CSU Addressing Accessibility Requirements Project (CAARP)

  • Formed to follow-up on the letter to Presidents from Dr. Blanchard
  • Designed to augment/complement and should support the strong foundation of your ongoing ATI projects, ATI staff, and annual ATI self-eval processes that campuses have been conducting for over 10 years
  • Plans should be submitted for review and approval to Chancellor White by September 6, 2019

Who handles issues around CSU compliance?

  • ATI
  • Office of Chancellor, general counsel
  • Audit