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Accessible Digital Media Guidelines - Educational Policies and Standards

Policies are now in place in several markets and jurisdictions that make accessibility a requirement for educational software. Each mandating agency generally establishes its own set of requirements, although the U.S. Federal government's Section 508 rules are rapidly becoming the example that many follow. Further, many publishers and developers of digital content for the classroom are finding schools increasingly interested in purchasing accessible materials. The No Child Left Behind (NCLB) Act was signed into law through the reauthorization of the Elementary and Secondary Education Act (ESEA) in 2001. NCLB requires K-12 schools to report the results of annual assessments of students' progress, disaggregated so that schools are accountable for adequate yearly progress of all student groups, including students with disabilities. Consequently, schools systems as well as individual teachers are under great pressure to advance the academic gains of students with disabilities and are therefore interested in purchasing materials that meet the needs of all their students. Information in these guidelines will help software developers meet the expectations of these policies.

U.S. Federal Government Requirements

ADA and Section 504
Two federal laws govern accessibility of education: Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 (as amended in 1998). All elementary and secondary schools and most postsecondary educational institutions are regulated under these laws. Title II and Section 504 have essentially the same requirements: institutions must be responsive to the needs of individual students and make programs and services accessible to them on request. Note that this differs from the proactive requirements of Section 508, discussed below, which state that all technology purchased by the federal government must be accessible whether it is initially intended for use by a disabled employee or not.

Regulations prohibiting discrimination in education are enforced by the Office of Civil Rights (OCR) at the U.S. Department of Education. Visit their Web site for more information on disability rights. Settlements made between educational systems and the OCR in response to complaints of disability discrimination have sometimes required the educational institutions to make system-wide, proactive changes in their procurement and use of instructional materials to ensure that textbooks and educational technology are accessible to students with disabilities. One such settlement was made with the California Community College systems (Docket #11-01-1132); statewide requirements in North Carolina for textbook accessibility are another example (Docket #09-97-6001).

Section 508
In order to ensure that its technology is accessible to its own employees and to the public, the federal government has created regulations based on Section 508 of the Rehabilitation Act that require that electronic and information technology developed, procured, maintained or used by the federal government be accessible to people with disabilities. These regulations apply to all federal purchases of technology. Requirements in Section 508 may also impact state colleges and universities, pending policy decisions from the Department of Education Office of Civil Rights. For official information on Section 508 see:

Federal IT Accessibility Initiative
The Access Board

The National Instructional Materials Accessibility Standard (NIMAS)
The National Instructional Materials Accessibility Standard (NIMAS) is a structured digital format for K-12 printed instructional materials intended for use in creating accessible books for students with print disabilities. "NIMAS refers to a collection of consistent and valid XML-based source files created by K-12 curriculum publishers. From these well-structured source files accessible, student-ready alternate-format versions of core textbooks (i.e.; braille, digital talking book, etc.) can subsequently be created," as explained further on the website for NIMAS at CAST.

CAST operates two centers in support of the NIMAS effort:

1. The NIMAS Development Center will improve the original standard by identifying new research and technological advances relevant to the standard. The center will also explore existing and new distribution models for the provision of accessible materials to students with disabilities.

2. The NIMAS Technical Assistance Center will work with key stakeholders such as states, school boards, and publishers to raise awareness of the benefits of accessible materials. It will also advise stakeholders on the efficient production and distribution of NIMAS-compliant materials.

The National Instructional Materials Accessibility Center (NIMAC)
To expedite use of the NIMAS files created by publishers, a National Instructional Materials Access Center (NIMAC) has been established in Louisville, Kentucky, at the American Printing House for the Blind (APH). The NIMAC is responsible for receiving and cataloging publishers' electronic files of print instructional materials in the NIMAS format. The center will provide these standardized files to authorized textbook providers, who will then produce textbooks for blind and visually impaired students across the country. The combination of a standard format and a central repository should significantly expedite the time frame in which textbooks are delivered to students who need them in the classroom.

U.S. State Policies

Numerous states have requirements for publishers to provide electronic files of printed textbooks purchased in the state. The Information Technology Technical Assistance and Training Center offers an Overview of State Accessibility Laws, Policies, Standards and Other Resources.

CAST offers the U.S. States and Territories Accessible Curriculum Survey, a summary of state and territory laws pertaining to the provision of accessible materials for K-12 students with print disabilities.

While those surveys cover accessibility of state government resources and of K-12 textbooks, less information is available about requirements for accessible multimedia and interactive software. However, two states that have instituted accessibility policies for a wider range of instructional materials are described below.

California Higher Education Requirements
The California Community College (CCC) system has released Distance Education Access Guidelines and Alternate Media Access Guidelines. The Alternate Media Access guidelines serve as a guide for the implementation of California law AB422 requiring publishers to provide textbooks in electronic format to all three systems of higher education in California (the University of California, the California State University, and the CCC). The Distance Education Access Guidelines serve as a guide for the implementation of the CCC's agreement with the U.S. Department of Education's Office of Civil Rights to ensure that students with visual impairments are given full access to distance learning in the CCC system. This document includes a summary of legal requirements as well as access guidelines for specific modes of distance education instructional delivery. The two sets of guidelines from CCC, and other resources, are available from the High Tech Center Training Unit.

In March 2004, the CCC distance learning accessibility requirements were incorporated into the general distance-education guidelines. This document was under revision at the time of this writing.

Maryland K-12 Educational Technology Requirements
Maryland enacted legislation in 2002 stating that any purchase of technology-based instructional products by school districts must include a requirement of equivalent access for students with disabilities, as defined by the Federal Section 508 requirements. This requirement has also applied to teacher-developed instructional materials since 2005. The regulations have been incorporated into the Code of Maryland Regulations (COMAR) 13A.05.02.13 H, Accessibility of Technology-Based Instructional Products.

Information on the Maryland State Department of Education's efforts to implement accessible technology for schools is available from the Instructional Technology and School Library Media Services Program and from the Department's page on accessibility standards.

Access For All: the Accessibility Metadata Standard
Fulfilling the promise of digital learning materials to enhance education at all levels requires helping educational software and publishing industries meet the needs of users with disabilities. This is not a one-time effort to fix a particular piece of software, but rather a shift in attitude to embrace universal design while being realistic about what can be achieved.

Making every piece of educational content fully accessible may not be entirely possible. The volume of material is great and while some types of media can be fixed easily, others require expert modification to ensure they provide an equivalent educational experience, particularly for learners with visual impairments. In addition, many resources that were created in the past are still in use but not easy to update. Improving the accessibility of as many resources as possible is, of course, an important goal, and teaching Web designers and curriculum developers the principles of universal design is crucial to making the next generation of materials accessible from the start.

Metadata for Accessibility
For any large collection of resources the greatest challenge is ensuring that users can find the materials they need among the many available, and this applies equally to accessibility. A solution for this problem comes from metadata.

The IMS Global Learning Consortium's Access For All Metadata Specification (AccMD) enables publishers and educators to record and share information about the accessibility of their resources and services. The metadata specification is designed to work in combination with a record of the user's needs and preferences as expressed in the IMS Accessibility for Learner Information Profile Specification (AccLIP). Together these are known as the Access For All specifications. Access For All is now in the process of becoming an international standard through the International Organization on Standardization. More information on the ISO standard is available from NCAM.

The Access For All specifications are intended to address mismatches between resources and user needs caused by any number of circumstances, including requirements related to client devices, environments, language proficiency or disabilities. They support the matching of users and resources despite shortcomings in resources. These profiles allow for finer-than-usual detail with respect to embedded objects and for the replacement of objects where the originals are not suitable on a case-by-case basis. The Access For All specifications are not judgmental but are informative; their purpose is not to point out flaws in content objects but to facilitate the discovery and use of the most appropriate content for each user.

Primary and Equivalent Resources
The Access For All metadata specification groups resources into two possible categories: primary resources and equivalent alternative resources. The primary resource is the initial or default resource. Most existing resources would be considered primary resources. An equivalent resource provides equivalent semantic and behavioral functionality and addresses the same learning objective as the referenced primary resource but in an alternative form.

Since the authors of most primary resources (and the authors of their metadata) are not likely to be informed about accessibility considerations and may not be motivated to create additional metadata, the metadata on the primary resources is kept to a minimum. Metadata regarding a primary resource simply describes what access modes are needed to use the resource (e.g., visual, auditory, text, etc.), whether the display and method of control is flexible, and whether there is a known equivalent resource.

Unlike authors of primary resources, it is anticipated that authors of equivalent resources are likely to be both motivated and informed about accessibility considerations. The description of the equivalent resource is therefore much more detailed and closely matches the AccLIP specification. This permits resource portals to search for equivalent content that overcomes a mismatch between the user's required sensory modalities and the modalities included in a primary resource.

For a more detailed description of the use of the specifications read the IMS Access For All Metadata Overview.

Using Accessibility Metadata
Integrating the accessibility specifications into infrastructure will require a number of coordinated efforts. Tools are being developed for authoring user profiles and resource metadata, or authors may be able to integrate the new data into existing personal preferences and resource metadata tools. Publishers and educators need to offer users the ability to record a set of accessibility preferences that can influence both the browsing interface and the way resources are located for the user. Finally, publishers need to add accessibility metadata to the metadata record for each resource, to the extent possible. The greater the amount of metadata available, the more powerful the system becomes.

Tools for authoring and using AccLIP and AccMD are emerging both inside and outside IMS. Publishers interested in a well-developed example (or even an open-source turnkey system) for an accessible digital library site should consider the Collection Workflow Integration System (CWIS) from the Internet Scout Project. CWIS offers a preferences editor for AccLIP data and transforms the library interface to match each user's preferences. CWIS can also edit and store AccMD data about resources and use them to highlight resources according to a user's AccLIP preferences.