ADA Compliance

Jun 05, 2011

Folks:

Just got back from vacation on a Sunday evening and was perusing through some of the evaluation reports that are generated through our LMS. 

We have recently (last 8-10 months) been publishing some online courses with audio content.  One of the individuals that took one of these courses commented that "for any audio portions of these courses, there should be text versions available, and to not provide this may be a violation of ADA Law".

I did a little bit of researching and have only been able to find that in order to be ADA Compliant, we need to be willing to make the accommodation, but nothing explicitly stating that for any training documentation that is audio in nature must also have a text version

Admittedly, I am no lawyer or compliance guru, so I am reaching out to some of you folks to see if anyone has any thoughts on this.  I have also reached out to our internal Legal / Compliance area but am wondering what folks here think.  Any thoughts are appreciated!!

TC

20 Replies
Gale Cossette

I believe this is true. There is a difference between Section 508 compliance and ADA compliance and unless you are a governmental agency, Section 508 would not be legally required.

ADA is a matter of a person establishing a disability and a need. It is up to the organization to accommodate, based on the disability. With regards to universities and higher educational institutions, proof of the disability must be met (documentations of assessments) in order to be approved as having a disability and then accommodations are provided (usually extra time on assignments, but there may be other accommodations). All facilitators are given a copy of this and they are required by law to comply.

Providing text with audio is highly recommended, as well as captions for all graphics.

Kayla Burtch

A lot of people just put the narration for the audio spoken into the "notes" tab. You can even rename it "narration" or "CC" in the player.

Another option which can be an and/or is to also provide a printable word/PDF file that includes the narration. We usually provide something like this, as many students find it helpful to have a non-computerized version of the information (Although we are sure to point out that this is a supplement and not a replacement for the online content)

Not sure about the "legal" aspect. But even from a non-disability perspective, it's nice to have the cc option for people who don't have the technical ability to play sound.

Gale Cossette

To all, best practices, in my opinion exceed what the law requires. If you consider the various needs to people in general, you will want to meet those needs. It is really nifty when someone who is deaf contacts you and states that they appreciate the captions. I agree with Kayla's comment about providing options.

Lawrence Tagrin

Gale Cossette said:

I believe this is true. There is a difference between Section 508 compliance and ADA compliance and unless you are a governmental agency, Section 508 would not be legally required.

ADA is a matter of a person establishing a disability and a need. It is up to the organization to accommodate, based on the disability. With regards to universities and higher educational institutions, proof of the disability must be met (documentations of assessments) in order to be approved as having a disability and then accommodations are provided (usually extra time on assignments, but there may be other accommodations). All facilitators are given a copy of this and they are required by law to comply.

Providing text with audio is highly recommended, as well as captions for all graphics.


Well, I am purchasing Articulate for use in a FEDERAL agency and Section 508 is the law for us.  The idiocy of not making the basic navigation compliant with the standard screen readers is going to force me to create at least two versions of each course in order to satisfy the law.  Don't forget that this law also refers to contractors who are developing training for Federal agencies and seem to be spreading to state and university users as well.

Kathleen Harper

Another one here creating e-learning for the government. But ADA isn't the only issue, workers in noisy environments also require the captioning. A recent project asked for captions that look like open captions (the type of "always on" captioning that appears on all screens of a clip with audio) and the notes/transcript column is what we usually use, but the project manager wants to really emulate the on-screen captioning. Having the notes appear from the bottom wasn't an option, as there is so much going on, on the screen content, at the same time.

One solution that would work in exactly that way was a series of thin 2-lines-of text boxes with the audio script that appear at the bottom of the content screens... a tedious production but one that when synched with the audio, works "just like" those captions. Only issue is that you can't make them closed captions/turn them off for users who *do* have a quiet environment or headphones... without creating a completely separate version.

Or can you?

(one option tossed around was creating the open captioned sequences in a program (cough)Captivate(cough) that includes the ability to do CC... but that opens up the tedium of THAT... and it all still needs to synch. We decided that the PPT captions would be a simpler - if tedious - way.)

Brian Houle

Kathleen Harper said:

...

One solution that would work in exactly that way was a series of thin 2-lines-of text boxes with the audio script that appear at the bottom of the content screens... a tedious production but one that when synched with the audio, works "just like" those captions. Only issue is that you can't make them closed captions/turn them off for users who *do* have a quiet environment or headphones... without creating a completely separate version.

Or can you?


Yeah, this is where it can get tricky.  If this were on my plate, I'd think about doing something with a bit of custom Flash to read in the slide notes from the presentation.xml then display them in the presenter panel or logo panel or something. But, then again, the timing of the appearance of the text to sync with the audio would be a challenge regardless.  I wonder if you couldn't somehow leverage the rather slick close captioning available in Captivate somehow, then import it into Articulate.

Kathleen Harper

And to answer the original question: It's good business and good design to create courses that can be accessed by those who need an alternative / equivalent experience for whatever reason; whether it be deafness, vision impairment, mobility issues, a noisy environment, a slow bandwidth connection, etc.


Since that's required of us, we often have to create a text-only version of courses that we have no other technology available to create. Which raises another question; how do you make a text-only experience an equivalent experience? My own interpretation is that if you only had an audio version of the course to listen to, with no support materials, would you understand the content? Good descriptions and accurate interpretation of visual content HAS to be part of the design for accessibility.

Kathleen Harper

Brian Houle said:

Kathleen Harper said:

...

One solution that would work in exactly that way was a series of thin 2-lines-of text boxes with the audio script that appear at the bottom of the content screens... a tedious production but one that when synched with the audio, works "just like" those captions. Only issue is that you can't make them closed captions/turn them off for users who *do* have a quiet environment or headphones... without creating a completely separate version.

Or can you?


Yeah, this is where it can get tricky.  If this were on my plate, I'd think about doing something with a bit of custom Flash to read in the slide notes from the presentation.xml then display them in the presenter panel or logo panel or something. But, then again, the timing of the appearance of the text to sync with the audio would be a challenge regardless.  I wonder if you couldn't somehow leverage the rather slick close captioning available in Captivate somehow, then import it into Articulate.


Hmm. Interesting idea. We're working with an older version (v4) of Captivate... anyway, thank you for the comment, it's got me thinking.

Joanne Lazzaro

HI, TC,

We are always cognizant of the need to have a full written text version of anything that is narrated. We do this in part because many of our learners work from cubicles, and have to turn the sound off (if they don't happen to have a headset handy) in order to avoid disrupting their neighbors. So in this sense we are ADA compliant  in that area, even though we do it for a different reason.

On a related topic, we have had to take steps to ensure that any "color coding"  that carries meaning (e.g. of tabs, buttons, words, etc.)  is either revised to be ADA-compliant (i.e. for "visual-color-impaired" individuals) or is also marked up with a text feature (i.e. asterisk, bolded, underlined, special font, etc) so that color is not the only key identifier. For example, one person wrote up a form where the instructions stated  "required fields" were colored red. We had to change it to "required fields are marked with an asterisk".

Joanne

Britt Coleman

Hi all,

We too are developing for government agency and can conquer most obstacles but one.  The final exam.  Does anyone have tips on how to make answering quiz questions suitable for sight impaired?  The assumption is having keyboard commands to move question to question, then select answers from multiple choice.

Any ideas are welcome! 

Brian Houle

Hi, Britt:

I've run into a similar situation.  I ended up doing up a simple javascript page that loaded quiz question and answer sets from an XML file.  That way, it would work with screen reader software because the output is straight-up HTML.  Of course, that project only needed a simple multiple choice "knowledge check" before continuing to the next section.

Britt Coleman

Hi Brian,

Thanks very much for the assist!  What a great find this forum is! 

We are still on the rocks regarding keyboard navigation between questions, answer selection, then recording score to LMS.  Admittedly, we know little about JAWS and other screenreaders at this point.  Perhaps that software manages keyboard navigation which would eliminate one of the obstacles.  Do you or anyone else in Articulate World familiar with this?

Any guidance in those 3 areas from the collective group is extemely appreciated!

Britt

April Edmonds

If you are doing any work for the Federal Government (contract or as an employee) by law you are supposed to make your projects ADA compliant (Section 508 standards). Many State and Local Governments have also adopted the Section 508 standards. I know in Florida in 2006, the legislature passed in law. W3C also has a Web Accessibility Initiative.

Flash is very difficult to make ADA compliant (looking forward to the HTML5 Articulate). However, as long as you can provide an "Alternative" that usually will cover you. If adding audio or video it should be captioned. 

Here are some links that might be useful:

Powerpoint

Word

PDF's

More on Microsoft Office 2010 Accessibility

Rhonda Bergamo

Using Storyline and Articulate Studio has definitely helped us create curriculum that is ADA compliant, Screen readers have no issue reading the content.

A situation has come up where close caption and providing text scripts is not an option. In some courses students need to transcribe the audio. Can anyone recommended a Speech to sign-language (video avatar) tool to use?

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