December 10, 2013

TEAM MEMBERS

Dominic Dorsey, Director of Accessibility, Chair

Klass Kwant, Video Content Production Manager, Co-Chair

Frank Conner, Department Chair, Psychology

Lyttron Burris, Professor of English

Sarah Rose, Coordinator, Disability Support Services

Kathy Keating, General Counsel

Paula Sullivan, Associate Dean, Faculty Evaluation & Hiring

MaryBeth Beighley, Director of Staff Development

Jeremy Osborn, Director of Center for Teaching Excellence

Introduction:The campus community of Grand Rapids Community College (GRCC) relies on administrators, faculty and staff to provide equal access to all programs and activities for individuals with disabilities. By providing ease of access in addition to reasonable accommodations to qualified individuals with disabilities, GRCC remains committed to adhering to the requirements of Sections 504 & 508 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of 1990 as amended (2008).

Our Responsibility:To ensure that members of the campus community are not excluded from participation or denied the benefit of information, advertisement or academic instruction. Communication mediums must be as effective for individuals with disabilities as they are for others. It’s about student success and accessibility to the community.

Statistics on Retention:1. College graduation - 12.8% of the hearing population

graduated from college whereas 5.1% of the deaf or hard-of-hearing population graduated. (http://

research.gallaudet.edu/Demographics/deaf-employment-2011.pdf)

2. As compared to a 47% dropout rate for students without disabilities, the college dropout rate for students with hearing impairments is 71%. (

http://www.handsandvoices.org/articles/education/ed/V13-1_beyondHS.htm)

Why We Can’t Wait:UC Berkley (1999), LaTrobe University (2008), Ohio State (2009),

University of Kentucky (2011), Daytona State College (2011),

University of Maryland at College Park (2013) all faced class action

lawsuits from advocacy and special interest groups like the National

Association for the Deaf for lack of accessibility in college resources

including but not limited to: Course Content and Classroom Environments,

Sporting Events and Entertainment; Safety, Emergency and any other

Announcements

National Association of the Deaf (NAD) vs. Netflix

-"...the court’s determination that Netflix’s streaming video service

qualifies as a “place of public accommodation” extends the jurisdiction

of the ADA to any organization that publishes video."

Audiovisual Captioning Policy• In accordance with the academic principals of equity and accessibility in

both the curriculum and in the campus community; a policy on the use

of audiovisual media must be implemented by the institution.Americans with Disabilities Act Requirements:• Title II mandates state and local governments:

• May not refuse to allow a person with a disability to participate in a service, program, or activity simply because the person has a disability.

• Must provide programs and services in an integrated setting, unless separate or different measures are necessary to ensure equal opportunity.

• Must furnish auxiliary aids and services when necessary to ensure effective communication, unless an undue burden or fundamental alteration would result.

• Shall operate their programs so that, when viewed in their entirety, they are readily accessible and usable by individuals with disabilities.

Benefits of an Audiovisual Captioning Policy• This policy would specifically benefit individuals who are Deaf or hard of hearing

who must have captioned media in order to access the auditory and visual media

from one location.

• Individuals with learning disabilities, ADD/ADHD, or other cognitive impairments

benefit from the open captions supplementing the audio

• Persons on this diverse campus where English is their second language benefit

from the captions as well as persons globally who see GRCC produced media

productions

• Enhance playback for viewers watching in noisy environments. Anyone in the

audience when variations of sound quality or surrounding noise cause distractions

would benefit greatly from captioning.

• Individuals without disabilities have stated that captioning helps in taking notes

and improves understanding and recall.

Proposed Policy Statement• To support an inclusive environment geared towards universal design

concepts which removes barriers and equalizes communication

access, all audiovisual media used as part of classroom activities,

instruction, distance learning, training modules for institution

personnel, campus sponsored events, and co-curricular activities

should be closed, open or real time captioned.

Changes and Revisions:

• Added definitions for Open, Closed, Real Time and Real Time Embedded Transcripts to the policy

• Added a section on Best Practices for the Captioning policy including:

– Captioning Required

– Captioning Encouraged

– Captioning Not Required

• Added item 4 under Procedures section for Impromptu Classroom Materials

X. Best Practices:– Captioning Required: if the uncaptioned video creates a

barrier to instructional material for a student who has a documented disability which would be accommodated by captioning or if the video is being shared in an unrestricted way (i.e. the video is publicly available). If you are not restricting access and you cannot be sure no one in the audience requires captioning, you must caption the material.

– Captioning Encouraged: Captioning of online video is strongly encouraged for any online video which will be used in the future for an undefined audience and even in cases where the current audience has been restricted to a group where it is unknown who will need the accommodation. For example, any audiovisual media used each time a class is taught should be captioned for future students who may need the accommodation.

X. Best Practices (cont.):– Captioning Not Required: Before coming to the

determination that captioning is not required, always inquire as to whether or not a video/clip/film is essential to a course outline.

Once this has been determined, given the current expense, captioning is not required for any online video that will be used for a limited duration when the audience is restricted to a group of users unknown to need the accommodation. If you are restricting access by some means and you are certain no one in the course is in need of captioning, then you are not required to caption the material.

*English language captioning is also not required in courses where foreign language or comprehension and recall of spoken word would be negated by the addition of these captions. However, if subtitles in the germane language are available, they are encouraged.

XI. Procedure4. Impromptu Classroom Materials

When utilizing Audiovisual Media in a classroom setting for the purposes of enhanced

learning such as YouTube, Hulu, Vimeo, or like online video streaming services, every

effort must be made to seek a captioned version of the video or clip. If a captioned

version is not available the remaining options include:

a) First, make a determination if the video/clip/film is essential to a course outline;

then

b) Seek an alternative video/clip/film with closed-captioning; or

c) Offer an alternative assignment to a student in place of viewing a non-captioned

video/clip/film.

d) If the video will only be utilized for a limited duration and the audience is

restricted to a group of users known not to need an accommodation, the material

is not required to be captioned. However, it is still recommended to exhaust

options a through c before making this determination.

Current Processes Supporting Policy Implementation:Captioning Request Procedure: The GRCC Media Department has an established

process and procedure for the conversion of audiovisual materials into an accessible

format. This office already responds immediately to accommodation requests

verified through DSS and as long as audio is discernable; files can be captioned in a

reasonable turn around.

Center for Teaching Excellence: Through workshop offerings in faculty professional

development, courses are offered in Camtasia Relay which shows participants how to

create recordings with editable automated captions.

Distance Learning and Instructional Technologies: In compliance with Web Content

Accessibility Guidelines (WCAG) issued by the World Wide Web Consortium (W3C)

and Section 508 of the Rehabilitation Act issued in the Untied States Federal

Government, we’ve instructed all faculty to adhere to accessibility standards

required under the Assistive Technology Act, Section 508 while creating and posting

Blackboard content.

Points to Consider• The purpose of this policy is not to penalize faculty members. The

spirit of this policy is to provide equal access to all members of the GRCC campus community.

• AGC policies are customarily passed with a grace period to establish procedure before implementation.

– (i.e. Admissions Application Cut-Off policy date of decision 4/10/12, Provost charged Student Affairs Office to develop implementation plan by Winter 2014)

• Policies give us the ability to advocate for necessary resources.

NEXT STEPS

1. Share once again with your departments.

2. Direct all feedback to ddorsey@grcc.edu by December 20, 2013

3. Committee will consider recommendations and make revisions to policy.

4. Policy will return to AGC on January 14, 2014 for vote.

Feedback/Questions: