Project Overview

The Americans with Disabilities Act (ADA) tasks all institutions with providing compliance in face-to-face (F2F), web-enhanced, and on-line courses for all students at the institution. The statement is derived from three important laws/regulations: The Americans with Disabilities Act (ADA) tasks all institutions with providing compliance in face-to-face, web-enhanced, and online courses for all students at the institution. (Title II, section 35.160 (a) (b), https://www.ada.gov/regs201O/titlell_2010/title11_2010_regulations.htm#a35160) The same document extends the requirements of section 504 of the Rehabilitation Act of 1973 to "to all services, programs, and activities of State and local governments, not only those that receive Federal financial assistance." Title V, section 504, (b)(2)(A) of the Rehabilitation Act (https://www2.ed.gov/policy/speced/leg/rehab/rehabilitation-act-of-1973-amendedby- wioa.pdf) specifically mentions "a college, university, or other postsecondary institution, or a public system of higher education" in relation to "services, programs, and activities." Section 508(a)(1 )(8) of the Act (https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards /section-508-standards) references the accessibility standards published by the Access Board, these standards were revised and published in January 2017 (https://www.access-board.gov/guidelines-and-standards /communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines#E205-content). The biggest revision to the section concerned section 1194.22, which updated the standards to the WCAG 2.0 level AA compliance (https://www.w3.org/TR/WCAG20/) and applied them to both web and non-web documents.


Compliance with these regulations calls for proper document formatting and graphic tagging, in addition to synchronized captioning of video. Captioning, in particular, can be an expensive proposition, especially as campuses find themselves with limited resources and funding for outside captioning services.


We proposed building a program to address ADA and copyright compliance in our Workforce courses to include web enhanced, hybrid/blended, and fully online formats. The model would rely on universal design principles to ensure courses are compliant for all students to include multiple learning styles to aid in persistence and completion. Our model will entail addressing in-house policies and procedures; setting up a review process to address ADA compliance in existing courses; building professional development courses to train faculty, student interns, and instructional designers on compliance regulations; creating a standard for faculty to use in building and managing their on line course design; and establishing an ongoing review mechanism to ensure all courses continually meet compliance goals. We see this project in various phases. Assisting us in this effort are two partner institutions--Texas State Technical College - Waco Campus and Alamo College District - San Antonio College. Alamo College District - San Antonio College has an academic structure that mirrors ours, with an Interpreter Training Program staff/students that also does captioning for the college. Texas State Technical College - Waco campus does not have an Interpreting Program but does have interpreters on staff that help with captioning on that campus. Both of these institutions will serve an assessment function and provide feedback on developed deliverables as to their adaptability and applicability to different college structures.
Our proposal is for Phase 1, which will bring together our instructional design team, ADA compliance office, interpreter trainers, and faculty engaged in online instruction to work as a team in addressing this effort. This team will build the model, then train and deploy student interns to aid faculty and the institutional design team in updating Workforce degrees starting with five high-use courses. These courses are as follows:

    • HITT 2235 — Coding and Reimbursement Methods
    • CRIJ 1306.87 — Court Systems and Practice
    • CDEC 1317 — Child Development Associate Training I (mix of user and 3rd party content)
    • CJSA 1308 — Criminalistics (this has some flash content that we will have to assess as well)
    • DAAC 1311 — Counseling Theories (3rd party content)

In follow-on phases, we will then focus our work on other Workforce courses and degrees including Health Professions programs. Our goal is to create a model that can be shared and applied at all community colleges across the state.


Our proposal require the following resources: additional training for instructional designers and interpreters; attendance at a national conference to expand our knowledge of ADA rules and best practices; training student transcriptionists to execute the program; and technology/software to aid in the translation work. Our goal and objectives align with the 60x30TX and Perkins Act requirements by building a model that can be initially replicated by 19 other institutions with interpreter training programs and with similar college structures. Nineteen community colleges in the state share the same academic structure that includes curriculum for an Interpreter Training Program. Those colleges should be able to make use of the deliverables with little or no modification. Other community colleges, those without an Interpreter Training Program, will still be able to use the deliverables. However, they will have to adapt those deliverables to whatever systems they have in place to address captioning needs on their campus or create an internal system that incorporates those adapted deliverables. Deliverables will be accessible to all community and technical colleges via a website. Our long-term our goal is for a model that will support all colleges in Texas. Additionally, we are building marketable skills and certificate options for students engaged in this work. Our ultimate goal is to ensure that we address all students within this special population with quality, fully ADA compliant courses and degrees.


The purpose of the Rehabilitation Act of 1973 was to ensure that federal agencies (501) and entities receiving federal assistance (504) were made accessible. Section 504 requires post-secondary educational institutions to be accessible to all students with disabilities and Section 508 requires all electronic and informational technology to be made accessible. In a traditional education setting, students, who have been approved for admission, and needing accommodations for various disabilities, would register at the office for Disabled Students. A designated person would document the disability and the need for specific accommodations prior to arranging in-class accommodations. This would generally entail an interpreter for Deaf or Hearing Impaired students, reading services for those that are blind or have a documented learning disability that impairs the student's ability to read and take notes. Videos used in class and needing accommodations were handled by the interpreter or the support person working with the student with the disability. Because of this, there were alternatives to having videos accessible by means other than captioning.


The advent of online or distance learning has changed the dynamics of how service is being provided. In the Fall of 2014, it was estimated that there were 5,750,417 students taking some form of on-line or distance education courses (https://nces.ed.gov/fastfacts/display.asp?id=80 ). According to the 2010 census (https://www.census.gov/prod/201 0pubs/acsbr09-12.pdf), 10% of the working-age population has a disability. Of that number, approximately 1.5% had vision impairments; 1.75% had some form of hearing impairment and 4% had some sort of cognitive disorder. Texas is named as one of the States having an above-average number of employment-age individuals with disabilities; however, even using the average number and extrapolating, it can be concluded that Texas has a large number of students with disabilities taking online courses. Because online courses minimize the stigma of having a disability via the fact that accommodations needed are not as obvious as to whom they are being provided for, the number of online students may actually be larger.


Although commercially produced materials for post-secondary instruction are created and marketed as being compliant with the Rehabilitation Act of 1973 and the 1991 Americans with Disabilities Act, the cost of purchasing compliant materials may be prohibitive. This is why many post-secondary institutions are looking to create instructional material in-house, especially for on-line instruction. At McLennan Community College, the provision of services to persons that are Deaf or Hearing Impaired is the responsibility of the Interpreter Training Department to ensure that appropriate accommodations are provided for the various levels of need, dependent upon the factors that impact Deaf or Hearing Impaired students. Initially, this consisted of interpreting and note-taking services, and then, as more students enrolled in on-line courses, captioning or interpreting of the videos produced in-house also came under the responsibility of the Interpreter Training Department. A natural extension of making videos accessible to persons that are Deaf and Hearing Impaired, was to assist in making videos accessible for other disabilities as well. The initial research by the Interpreter Training department regarding best practices for captioning revealed that this is an issue for many colleges. Many have tried making videos accessible in 'house but quickly became overwhelmed by a variety of factors, and now, most contract out these services. As the number of students taking on line courses grows, the number of students with disabilities taking these courses will grow as well which means the need for accessible media will continue to grow. Data gleaned from the proposed project's research will allow institutions to make better-informed decisions regarding making their materials more compliant and accessible. It will also aid those wishing to do the work in-house with best practices on how to do so.


An additional benefit are the marketable skills that student workers will gain from participating in this grant project. A quick look at the employment picture surrounding skills used by students in this project reveals there are approximately 200 positions with public and private entities just in Texas related to making digital media accessible. As the need grows, so will the need for trained personnel; i.e. "Digital Accessibility Support Specialists." Whether an institution decides to contract the service out or provide digital accommodations in-house, there appears to be an emerging market for the type of skills that will be developed and documented through this project.
We see this model addressing many of the objectives laid out by the 60x30TX initiative. First, the course redesign will help student interns in expanding their marketable skills and completion. Students working on this program will graduate with a greater degree of workforce readiness due to expanded marketable skills and potential certification. Second, it will create ADA compliant courses to aid an under-served population of students with special accommodation needs (i.e., deaf, blind, learning disabilities, etc.) to complete and earn a certificate or degree, addressing students to aid with persistence and completion-a Perkins Act requirement. Finally, all students will benefit from the additional accessibility these courses will provide which will ultimately lead to greater student success and completion.