Background
Scope
Methodology
Qualifications of individuals participating in the EITA audit
Dan Bowling, EITA task force
Courtney Damron, EITA task force
Lucy France, UM Legal Counsel
Bernadine Gantert, EITA task force
John Greer, EITA task force
Zan Olsen, UM IT Accessible Technology Services
Aaron Page, UM IT & UMOnline
Janet Sedgley, EITA Coordinator
Marlene Zentz
Barb Seekins
Announcements and Education
Audit
Campus Online Self-study forms
Timelineof activities
Compilation and Testing
Observations/Data
Online Survey
Web sites
Web site audit results: courses
Document audit results: departments
Document audit results: courses
Document accessibility features
Media audit results: departments
Media audit results: courses
Software audit results:
University websites
Websites with essential student functions
Random review of UM websites
Documents posted to webpages and websites
Peripheral campus web servers
Application processes
Library services
Acquisitions (Library purchases)
Digital Collections and Institutional Repository Materials
Interlibrary Loan
Paw print
Reserve
Website
Learning Management Systems
Chat rooms and forums made accessible
Description of Each Aspect of the Learning Management System
Strategy for the Ongoing Accessibility of the Learning Management System:
Access to classroom podiums and liquid crystal display devices
Controllers:
Podiums:
Course registration software: Cyberbear
Videos
Personal response systems (“clickers”)
Banking arrangements offered via websites and ATM access
Next Step: Corrective Action Strategy
Appendices
Appendix A: Audit Forms
Departments
Documents (dept)
Software/Hardware/Systems (dept)
Hardware
Web (dept)
Media (dept)
Instructional Materials
Appendix B: UM Web site review process
Appendix C: UM Web sites published with the new template
Appendix D: Student critical web sites/functions
Sites, Services and software
Academic sites:
Support sites:
Central IT supported:
Appendix E: Flash files on web server
Appendix F: How websites were selected for random review
Appendix G: Admissions – Hobsons software
Background
In Augustof 2012, the University of Montana received notice of a complaint from the United States Department of Education’s Office for Civil Rights (OCR). The OCR summarized the complaint as follows:
OCR received a Complaint of disability discrimination against the University of Montana on May 4, 2012 (OCR Reference No. 10122118). The Complaint alleged that the University is discriminating against students with disabilities by using inaccessible electronic and information technology, including: inaccessible class assignments and materials on the learning management system, Moodle; inaccessible live chat and discussion board functions in the learning management system, Moodle; inaccessible documents that are scanned images on webpages and websites; inaccessible videos in Flash format, that are not captioned; inaccessible library database materials; inaccessible course registration through a website, Cyber Bear; and inaccessible classroom clickers.
(Item 1B, Resolution Agreement).
On March 7, 2014, the University entered into a Resolution Agreement with the Office for Civil Rights.
This audit report is prepared in accordance with Resolution Agreement Items III.G.and IV.G.which state as follows:
III. G. EIT Accessibility Audit:
1. By June 6, 2014, the University shall complete an accessibility audit of its EITs that will examine the accessibility and usability of the EITs provided by the University to students, prospective students, faculty, and staff who have disabilities. The audit shall examine various aspects of the University’s EITs, including but not limited to, University websites, documents posted to webpages and websites, application processes, library services, learning management systems, access to classroom podiums and liquid crystal display devices, course registration software, videos, and videos in Flash format, personal response systems (“clickers”) and banking arrangements offered to students, faculty, and staff, including website and ATM access.
2. The audit required by Section III.G.1. of this Agreement shall be conducted in a professional manner in consultation with an individual or individuals who is or are knowledgeable about access to EIT by students, faculty, and staff with disabilities. The audit will also be benchmarked by appropriate processes.
IV. G. Report about EIT Accessibility Audit. The report will include a copy of the audit, the name, title, and relevant qualifications of the individuals involved in the audit, the methods the University used to conduct the audit, and each EIT audited.
Scope
The accessibility audit included the entire Missoula “Mountain” campus plus two remote campuses – Bitterroot College and Missoula College with a focus on educational and student-centeredactivities and materials.
Methodology
The general approach was to widely disseminate information about EIT accessibility and to request input from all levels of the campus community. This meant incorporation of both top-down and grassroots approaches, since both have proven successful approaches to changing technology in the past.
The top-down approach involved an EITA task force which visited larger departments and general campus constituency groups. The grassroots approach involved contacting technical staff and departmental leadership.
In addition, the EITA continuously supplemented audit activity with education to help departments adjust to the change. Likewise, educational materials always included reference to the audit. For example, all departmental meetings included a large measure of education and predominantly a question-and-answer approach. Audit forms also included an open comment section and several questions where departments or individuals could request further information or departmental workshops.
Qualifications of individuals participating in the EITA audit
Dan Bowling, EITA task force
Dan Bowling is currently the Web/Database Administrator for the Division of Student Affairs. He has 9 years of professional experience working with accessible web technologies in higher education. His current position includes regularly evaluating web-based software for accessibility, including a recent partnership with George Kerscher, an internationally acclaimed accessibility expert, to evaluate an enterprise-level student conduct system.
Dan has provided many in-house training sessions to UM software developers regarding WCAG 2.0, and provides ongoing training to staff web editors on building accessible websites with the university’s web content management system. Dan was also a featured conference speaker on the topic of web accessibility at the Big Sky Developers Conference in 2012, and hosted a web accessibility discussion session at the Missoula Accessibility Camp in 2013.
Dan’s resume is located at:
Courtney Damron, EITA task force
Courtney is a student who just graduated from the University. She was the Director of the student group that advocates for students with disabilities, Alliance for Students with Disabilities (ADSUM). She has been a research assistant at the Rural Institute at the University of Montana. She has also been a student employee at the Office of Disability Services for Students. She has been the student representative to the ADA/504 Committee.
Lucy France, UM Legal Counsel
Lucy is current the University’s legal counsel. From 2008 to 2013, she served as the Director of Equal Opportunity & Affirmative Action. She has 20 years of experience practicing law and much of that has been practicing in the areas of discrimination and employment law. She has taught employment law as an adjunct professor at the University of Montana School of Law. She has given numerous legal presentations and training sessions for practicing lawyers and business managers on discrimination law. When she was in private practice, she gained experience drafting and revising employment related policies and procedures for a wide variety of business clients.
Bernadine Gantert, EITA task force
Bernadine Gantert has been employed in Disability Services for Students for almost 30 years. She served as the main coordinator for the architectural accessibility audit completed in the 1990s and currently serves on the EITA task force.
John Greer, EITA task force
John Greer isHead, Technology & Systems Services of Mansfield Library. He is a member of the EITA task force, a member of the IT Senate and the chair of the IT Senate’s Enterprise systems .
Zan Olsen, UM IT Accessible Technology Services
Zan has a Bachelor’s degree in Computer Science from the University of Montana. He has worked for MDAC for 1-2 years as a technology trainer. He worked as a programmer for 20 years in Enterprise Information Systems in the University of Montana’s Information Technology Department. Since spring 2014, Zan has served as an Technical Accessibility Expert in Accessible Technology Services. He brings years of personal and work experience in accommodations, assistive technology and information technology and currently serves as coordinator for the accessible technology procurement project.
Aaron Page, UM IT & UMOnline
Aaron Page is a Junior at the University of Montana School of Business Administration, with a major in Management Information Systems. Aaron lost his functional vision in 2009, at which time he attended Lions World Services for the Blind in Little Rock to study Independent Living and Assistive Technology skills. Aaron began studying at the University of Montana in 2011, where he has served as a Student Accessibility Specialist for UM’s Learning Management System, a technician for UM’s IT Helpdesk, a student representative on UM’s Americans with Disabilities committee, and a member of UM’s Electronic and Information Technology Task Force.
Janet Sedgley, EITA Coordinator
Janet has years of teaching and training experience in computer applications, communicating with computers, and electronic publishing. She has been the computing and information services help desk manager at the University so she has an intricate knowledge of the needs of users and resources available at the University. She has managed other large scale projects related to changes in campus technology. She has worked as a systems analyst supporting campus web resources. For many years she worked with Disability Services for Students to maintain the specialized technology for students with disabilities. She also assisted students to match their needs with available options and tutored them in their final selections. She is member of the University’s ADA/504 Team and chairs the Daisy Consortium’s subcommittee on Consumption of Epublications through Reading Systems availability/accessibility for the Transition to Accessible EPUB Working Group. She is skilled at providing captioning, document tagging, testing for software website accessibility, and research and development for accessible education technology. She is conversant in American Sign Language. Additional information is found at:
Marlene Zentz
Marlene is an Instructional Design Consultant and Accessibility Specialist for UMOnline at the University of Montana. Her biography is located at:
Barb Seekins
Barb has been employed by the University since 1990. Her first positions were with the Rural Institute on Disabilities as a Program Officer and Research Specialist responsible for closing out the Montana Supported Employment Demonstration Project, a grant from the State of Montana, and gearing up the newly funded MonTech program, a grant from NIDRR. In 1992 she was hired as a Research Specialist to conduct the first ADA Self Evaluation and Transition Plan. This was adopted in 1993. Since then she has been a member of the ADA/504 Team and Chair since 2000. She has also been a member of the EIT Task Force and EIT working group since their inceptions.
Announcements and Education
In order to begin the audit and self-study process, the EITA Task force first started to reach out to individual departments informally, beginning in late 2013. The goal was to announce the anticipated Resolution Agreement and audit to the campus community, and to help facilitate the upcoming changes.
As the conversation developed and questions arose, EITA visited various departments in an attempt to answer questions and provide education. EITA also sent out several notifications announcing the study. The first query included a statement from the Chief Information Officer (CIO) demonstrating support for the self-study/audit. EITA later sent out a statement referencing the resolution agreement. Multiple departmental level queries went out announcing the study, at first with a quote from the CIO that demonstrated support for the self-study/audit and then later referencing the resolution agreement.
Additional efforts to announcethe coming Resolution Agreement and audit to campus included a presentation to the Academic Officers, and two presentations at the Faculty Senate, Staff Senate, and Technology Associates Group (groups involving office managers and campus front line staff). EITA also presented material to the Provost Office twice and met personally with individual departments.
EITA met frequently with Technical Partners, a UM group that partners local technology support staff with central IT.As a part of this partnership, EITA led several discussion sessions focusing on each of the selected categories referenced in OCR’s notice of the complaint. In addition to these efforts, Tech Partners provided information about EITA activities at most of their monthly meetings. In two sessions focusing on software procurement, for example, Tech Partners highlighted the importance of EITA compliance. In addition, EITA has met individually with departmental technical staff from across campus.
Audit
Before the audit officially began, the EITA coordinator provided particular departments with a “pilot study” or test audit. This was intended to help departments prepare for the actual audit. Of the seven or eight departments contacted, only few responded. Of those, two or three asked if web forms were available and two were willing to participate in interviews and a group meeting with faculty. The EITA staff used this information to refine and augment audit questions and to develop web forms for the audit.
The informational webpage created for the audit featured a contact and comment page as well assections outlining, in detail, accessibility requirements and guidelines for web, media, documents and software. In addition, EITA created an instructional materials audit form containing questions about each of these areas, with the questions being tailored toward course usage. The UM Accessibility page ( included buttons that lead directly to the first departmental form (contact and comment page) and to the faculty’s instructional materials form.
Before and during the audit, the EITA Coordinatorand EITA task force members all worked to widely disseminate information to the campus community about the audit requirement and the locations of the forms. The EITA Coordinator sent email to departmental chairs or directors and followed up when there was no response. When the EITA Coordinator made contact with anyone in a department, the coordinator ensured that individual emails were sent directly to all faculty within that department. This method of contact was used based on multiple comments that the EITA Coordinator was unknown to some faculty and that the mandate to complete should come from departmental leaders or technical staff.
Near the end of the semester, EITA sent emails to individual faculty within the departments visited. During the week before finals, most faculty on campus received reminders in their departmental mailboxes designed to stand out from all of the regular mail. In addition, EITA contactedall deans at UM and asked them to disseminate information about the audit and forms to their departments.
EITA also hosted open lab times (with an online webinar option) during the semester. These were less successful than the direct communications. Three similar sessions with refreshments were offered during the final week of the audit. Attendance at these sessions was moderate.
UM Faculty and staff shared information through interviews with department chairs and front office staff, forms, and occasionally through individual interviews. During group sessions with faculty the EITA coordinator also gathered information. Originally these meetings were seen as a time for faculty to fill out the forms while asking questions. However, during the first few sessions so many questions were asked that there was no time left for other activities. Each session ended with strong encouragement about what faculty should do next – i.e., fill out the forms and start converting their documents.
Audit activity largely ended on Friday June 6, 2014, although a few people found and filled out the forms after that date. The information gathered from audit web forms is included in the relevant reporting sections below and summarized in the appropriate sections below.
Campus Online Self-study forms
In order to address department-specific issues, the EITA coordinator, Janet Sedgley, met with several individuals from various departments and gathered general information about what accessibility categories existed within departments. From December 2013 through early February 2014, EITA researched accessible web-based survey options. EITA decided in late January to use locally developed web forms from the University’s content management system. In February EITA developed forms which were reviewed by the committee. The forms are listed in AppendixA.