15 Years After An OCR Suit: NC State’s Accessibility Refresh

Slide Deck

In 1999, NC State University entered into a voluntary resolution resulting from three complaints filed from the Department of Education Office for Civil Rights (OCR). The resolution agreement resulted in the creation of a campus-wide IT accessibility policy, an accessibility coordinator position, and other essential accessibility resources that were relevant at the time.

But what does accessibility at NC State University look like 15 (actually 17) years later? After so much time, it would be easy to fall behind or fail to maintain the established accessibility standards.

In this session, Grey Reavis (University IT Accessibility Coordinator) and Rebecca Sitton (Assistive Technology Coordinator) will look at how they are creating a proactive strategy to address the current risk areas on campus.

This presentation will cover:

  • The OCR complaints and the major initiatives that came out of them
  • NC State’s risk assessment process and current initiatives
  • How awareness of OCR complaints influences campus climate and changes
  • NC State’s campus-wide accessibility policy
  • Faculty training
  • Working to make accessibility a proactive priority on campus


Grey Reavis
University IT Accessibility Coordinator | NC State University

Rebecca Sitton
Assistive Technology Coordinator | NC State University

Lily Bond (Moderator)
Director of Marketing | 3Play Media

Webinar Insight: How to Bounce Back from an OCR Complaint

In the world of higher education, North Carolina State University is known for their innovation in engineering, science, and technology. So as the digital age was emerging in the late 90s, NC State began to transition their content into the online world.

But while their libraries and classrooms were becoming more digital, much of the administrative paper work on campus was still on paper, until 1999 when three students with vision loss filed independent complaints with the Office for Civil Rights (OCR).

The lawsuit alleged the university discriminated against them based on their disability because they were unable to view information posted on paper such as bulletin board postings, dormitory notices, and paper mailings.

Through these complaints, NC State entered into a voluntary agreement to provide access to all university notices and course content comparable to all students, as well as implement assistive technology so all students on campus would have equal access to the same technologies and announcements.

By implementing the following steps (in no particular order) they got to work on greater campus accessibility.

Step 1: Establish a permanent full time positions dedicated to managing on-campus accessibility.

Initially, NC State had one full time position dedicated to IT accessibility labeled as the Coordinator of Assistive and Information Technology. Then they realized the position would be more efficient if it were split into two: the IT Accessibility Coordinator and the Assistive Technology Coordinator.

The IT Accessibility Coordinator position at NC State is tasked with ensuring the accessibility of the software and hardware used on campus. This individual works with developers, faculty, content creators, and administrators to consult on the accessibility of projects, organize trainings, and set policies to ensure a barrier-free IT environment for everyone.

The Assistive Technology Coordinator is tasked with making sure students have access to campus technologies. Both the IT Accessibility Coordinator and the Assistive Technology Coordinator work together to keep the university in line with its accessibility initiatives and act as middlemen between all departments.

Step 2: Amend computer use policy to establish guidelines for official web pages to ensure web pages and other course related content is accessible to persons with vision loss

With the advent of new technologies in education, it’s important to keep IT policies up-to-date with all technologies present on campus to ensure people also understand accessibility regulation is applied to them, as well. One of the most effective ways to do this is by simplifying the language, so that all departments are on the same page. For example, at NC State, the language was changed to apply to all members of the community including teachers and staff, not just individuals who worked with accessibility.

They even took the regulations a step further and used proactive language so that teachers and staff could integrate accessibility initiatives into their workflow even if no current students had requests.

To help web developers work towards greater accessibility, NC State invested in an accessibility scanner. The scanner has helped ensure web developers can easily stay compliant with WCAG 2.0 and Section 508.

Step 3: Restructure the Disability Services Office (DSS) to report to the provost office.

Before the restructuring at NC State, the Disability Services would report to the Division of Student Affairs, now they report to the provost office. This in turn has created executive level backing for NC State’s disability initiatives.
Step 4: Find funding.

Funding is key when implementing an accessibility initiative. As Rebecca Sitton, Assistive Technology Coordinator at NC State says, “If you lose funding for positions, or you lose funding for technology, it could result in stagnis or just not the progression that you need to see with all these rapid advances in technology and how we’re delivering education now.”

After the complaint, the university provided additional assistive technology funds through their educational technology tuition fee. This included $90,000 for assistive technology purchases, a significant increase from the $30,000 the DSS originally received.

NC State also uses an interesting method for captioning. They have set aside an Education Technology Fund (ETF), which is financed by tuition fees from every student. Through this methodology the university has been able to acquire $60,000 a year for captioning. But since the funding is not enough, they have established an ETF committee that analyzes all material requested for captioning to justify the need.

Furthermore, NC State has locked standard rates for the university and has created a list of vendors that departments can work with to facilitate the workflow for accessibility.

Step 5: Enhance assistive technology center in the library.

To ensure all students have equal access to the materials in the library, NC State enhanced the assistive technology center in the campus library. The center includes JAWS workstations, a Kurzweil 1000 reading machine, and an additional CCTV. All technology is kept up-to-date.
Step 6: Amend on-campus policies to include disability-related complaints.

First, came the amendment of the student grievance policy, which was changed to include disability-related complaints. Then, along with the grievance policy amendment, came the establishment of an ADA advisory committee to ensure disability-related input from students, faculty, and administrative units on campus is acknowledged.

And like a butterfly effect, other policies were also amended, such as requirements for course syllabi (which includes a disability statement directing students to the DSS for assistance), and a policy on discrimination, harassment, and retaliation complaint procedures.

Step 7: Train faculty.

As is the case with captioning in higher education, the main barrier to accessibility initiatives is often a general lack of awareness. Most faculty are simply not aware that they need to caption content or provide alternative formats for certain documents. The first step to mitigating this barrier is through greater awareness and faculty training. For example, you can begin integrating accessibility to faculty onboarding, or hold monthly accessibility workshops for more tenured faculty.
At NC State, they have created a comprehensive website with guidelines on creating accessible course materials. They are also developing an online faculty course on accessibility. In addition, they have partnered with the Distance Education Learning Technology department to develop a faculty workshop series that runs like an online learning group and offers faculty in-person workshops on major issues in the classroom, such as creating PDFs or captioning videos.
Overall, it takes time to achieve full compliance, but adoption often comes quickly once you build awareness. Even if you haven’t received an OCR complaint, taking a proactive approach will put your university in the forefront of greater accessibility. What you will quickly realize is that the whole community can benefit from accessibility initiatives.

Webinar Q&A: NC State’s Accessibility Refresh

15 years after entering into a voluntary resolution from three OCR complaints, NC State University has come a long way with their accessibility initiatives on campus.

Read on for some thought-provoking insight into their current operations from the audience Q&A, and watch the full webinar above.

How did you develop the faculty training? And what was the reaction among faculty? And is it mandatory?

GREY REAVIS: At NC State, there is no mandatory accessibility training for anyone. But we found the need, and so that’s part of the reason that we developed the faculty workshop series. The workshop series is based on both informal surveys that we did with faculty members on campus, along with adult learning principles, et cetera, and also just kind of figuring out what we think faculty should actually know.

There’s quite a spectrum of information when it comes to accessibility. And so what we try to do is to narrow it down to what would have the biggest impact for the time that they were learning. We do six simple ways to make things accessible, and those are platform agnostic. So if they’re in Moodle, which is our learning management system, if they’re creating a Google Doc, if they’re using Microsoft Word, PowerPoint, whatever they’re using, here are some techniques that they should always be looking at. So that’s color contrast, text, structuring with headings, et cetera.

And then we look at the other big things that we saw in terms of major issues on campus, which we see a lot with documents. There’s still a huge number of documents, especially PDFs, being distributed to students either through email or through the learning management system. And so we gave them specific training on how to make sure that their documents and PDFs, when they made them, are accessible.

And then we looked at videos. Because we find that, especially as online learning increases, that more and more folks are creating instructional videos. So we want to make sure they know how to create one upfront that has accessible things, and then be able to provide captioning and audio descriptions depending on what they need.

And so those are the big areas. That doesn’t mean we hit everything. But we’re trying to hit the things that faculty are more likely to be able to adopt, especially since they don’t necessarily have design background, and distribute that.

So far, it’s been received pretty well. We asked them at the end to create a specific project they’re going to work on, like maybe they’re going to make their syllabus accessible, or they’re going to create a new introduction video that has the accessible techniques in it. And it seems like taking those bite-sized chunks makes it easier for them. And we’ve gotten a pretty good response based on that.

If you have a learning management system (LMS) with online courses, how do you train your online faculty to ensure that the courses are accessible for both blind and deaf users? Do the faculty build their own content? And if they do, are they required to have accessibility issues taken care of?

GREY REAVIS: When it comes to online classes, ultimately, faculty are responsible for creating their materials. And oftentimes, they’ll work in conjunction with DELTA, our online learning group. DELTA sometimes provides training, and then the accessibility office also provides training for faculty. Ultimately, it’s their responsibility. And we try to provide them both training and resources to make that accessible.

REBECCA SITTON: We have the trainings for faculty. We’ve done checklists that we’ve put out there for faculty to use when they’re creating their courses to use as a guideline. We also have set up a captioning grant so that as they are looking for content, if it’s not captioned, we’ve provided pretty good instructions and way to get funding for that through our grant. It’s a process.

There have been courses that have been online for several years that haven’t been checked. So we are occasionally coming up against materials that we need to convert. I’d love to live in an ideal world, where every course and every page that’s up inside of a course management system or learning management system is accessible. But I think we have a responsiveness and a plan that we all work together.

And that’s where those key strategic partnerships come into play. I communicate as the person in disability services that has some general awareness as to who’s enrolled in courses, a method to let our online learning system know really which courses to check really well early before the semester even starts.

So I think between our education that we’re doing to faculty and our checklist and our communication, our grant provision, those are some things that you may look at doing your own university to help you out.

In terms of accessibility, design, and techniques, how long did it take the faculty and staff to adopt to these changes?

GREY REAVIS: Because the accessibility coordinator position is located with information technology, which is primarily a staff-focusing group, a lot of the initial work was working with developers in particular, looking at both websites and enterprise software that they were developing, and distributing across the university. And so there was a lot of work with that.

It takes time, but like Grey said, adoption comes pretty quickly once they’re made aware. I think faculty are really good about wanting to do it right.

Now that IT is spread across the university, what we’re seeing is that we need to work more closely with faculty, make sure they have the key skills and knowledge to develop content and select content that is accessible. Instructors are not out there purposely not designing things that are not accessible. So we have to be able to provide them with enterprise tools and with guidelines so that they can do the right thing.

But we are a very distributed campus with over 10,000 staff and faculty members. So yeah, it takes time, but it works.

REBECCA SITTON: It takes time, but like Grey said, adoption comes pretty quickly once they’re made aware. I think faculty are really good about wanting to do it right. But again, we come from a technical world here, Grey and I. Our humanities faculty may not be as used to using technology. And so once you point out or you help them, they tend to get it pretty quickly and develop their materials and responsiveness pretty well.

Have you set up a process for dealing with purchasing exceptions?

GREY REAVIS: With our purchasing process, since we just started out, our big focus is on purchases over $1,000 and purchases that are used by larger groups on campus, let’s say. And what we’re now working on are conditions of approval.

Let’s say, for instance, we’re working with a piece of software where the interface is accessible but there are certain features that are not. So we’re working on a process of defining what those conditions are and having the purchasers– the people in charge of whatever the purchase is– create an equally effective alternative access plan, so they know what they’re going to be expected to do before it’s ever an issue.

And in that way, we’re hoping to encourage folks to more and more begin to have conversations on their own with vendors, rather than waiting for it to get to the accessibility office and us starting the conversation. We do expect that to take more time to do that. But that’s kind of the goal.

How is the captioning grant funded? And what was the process to acquire the grant?

GREY REAVIS: So the captioning grant is funded through Education Technology Funds (ETF). They’re basically fees that every student pays. And it’s tuition and fees, so part of that falls into there. And so we were able to acquire $60,000 a year for captioning. And depending on your role at the university, when I say $60,000, that may sound like a lot, or it may not sound like a lot.

But what we’ve been able to do is to use that to both fund some captioning that’s been requested by students and some that’s proactive. Our goal is to get as much proactive captioning as possible, especially for high impact classes.

There is a committee for ETF funds. And based on research that happened, it was clear that the best way to get funding for captioning or any other types of things in that way was to go through this committee and justify it. And that’s basically how it happened.

Need help getting funding for captioning? Download and read our inforgraphic: 5 Stats to get administrative buy-in for captioning

It’s really that the previous coordinator that secured the grant knew some of these key stakeholders and was able to make connections with them and to get buy-in from those folks in order to secure the funding.

REBECCA SITTON: And I’d also add that we’ve done a pretty good job at creating vendorships and getting standard rates for the university. So we’ve already worked through the vendorship and the partnerships so that we have a list of vendors that departments can go through to get their videos captioned. It’s a pretty easy process.

Do faculty have to apply to get videos captioned proactively? Is there a prioritization process?

GREY REAVIS: If they want to work through the captioning grant, they do have to apply. And there are certain criteria that we look at. So let’s say we get 25 faculty members requesting proactive captioning over the summer. We’re going to give that to as many courses that we can.

But when we have too many requests for funding, we tend to look at the type of class it is. So is this a gateway class, a class that everyone’s required to take? How many students are in it? Are these videos that have been created intentionally based on good instructional design techniques that are intended to be used for the next couple of semesters? Or are these things that are just recorded in the classroom without editing?

And it’s basically looking at instructional intent, quality of the videos, and then impact it’s likely to have on students when it comes to priority. We want to give it to everyone, but sometimes we do run out of funding. So they do have to apply and let us know those facts.

17 years after this OCR complaint, what would you say is your biggest accessibility challenge today?

I think that the biggest challenge right now is staying abreast of all the information and the resources that are available to faculty.

GREY REAVIS: Well, I think that the area that I think is really interesting to try to focus more on was looking at more of the new emerging instructional technology, especially the ones that instructors are able to select and use on their own. I’m an instructor, let’s say, in my English class. And I’m like, ooh, I found this really cool thing. And I can accept and use it without having to pay for it or talk to anyone about it, and really kind of making sure that we’re supporting faculty members in that selection, so they know what to look for.

REBECCA SITTON: And that’s kind of my opinion as well. When I’m working with students and getting prepared for each semester, and we’re working with faculty, I am still amazed at the new publishers’ materials, their interactive websites, their supplementals. And so again, I think that the biggest challenge right now is staying abreast of all the information and the resources that are available to faculty.
The public-facing websites I don’t really concern myself with. Web design is pretty well taken care of on campus. And our content creators, I think, are covered and being trained to create accessible design. But I think the biggest barrier that I see in how we’re going to have to adjust and figure out a way is course content for students, given new polling software that comes out, again, all kinds of interactive Chrome extensions.