February 11, 2014

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.

Legal Precedent: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.

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.“

U.S. Department of Justice Civil Rights Division Disability Rights

Section – Effective Communication - Covered entities must provide

auxiliary aids and services when needed to communicate effectively with

people who have communication disabilities

The Americans with Disabilities Act requires GRCC to ensure access to equal and effective communication for all students, staff, and community members. This policy would:• Ensure compliance with federal law

• Benefit individuals who are deaf or hard of hearing who must have captioned

media

• Support an inclusive environment geared towards universal design

• Benefit individuals with learning disabilities, ADD/ADHD, or other cognitive

impairments

• Benefit persons learning English as their second language benefit from the

captions

• Benefit persons who see GRCC produced media productions.

• Benefit individuals without disabilities who have stated that captioning helps in

taking notes and improves understanding and recall.

• Benefit anyone in the audience when variations of sound quality or surrounding

noise cause distractions.

Changes and Revisions:• Strengthened Proposed Policy Statement and Definitions

• Changed “Best Practices” to “Guidelines” with examples under each section including:

– Captioning Required: Purchasing New Audiovisual Media/Instructional/DVD/Film, Creating Audiovisual Media, Continually Utilized Audiovisual Media

– Captioning Advised: Currently Owned Non-Captioned Video/DVD/Film Releases, Classroom Projects/Student Produced Media

– Captioning Not Required: Impromptu Classroom Materials, (Foreign Language Exceptions)

• Referenced Documents: U.S. DOJ – Effective Communication, Copyright Permission Request Form

• Addition of Remediation Process

Proposed Policy StatementAll audiovisual media used as part of classroom activities, instruction, distance learning, training modules for institution personnel, campus sponsored events, and co-curricular activities should include either closed, open, real time captions, interactive transcription, or subtitles; whichever is appropriate.

X. Guidelines (Abbreviated):• If it will be recorded and shown for the foreseeable future:

Captioning Required

• If it's a previously owned video that we'll use in the future: Captioning Required

• If it's a previously owned video that can or will be replaced with an accessible version: Captioning Advised

• If it’s a student produced media for a defined audience where no one has self-identified as needing the accommodation: Captioning Advised

• If its shown for a limited duration, to a restricted audience where no one is known to need the accommodation: Captioning Not Required.

• If it's a YouTube clip shown the day after an event happened (impromptu), no one is known to need the accommodation and attempts at a.) finding a captioned version online, or b.) finding an equally effective alternative have both failed?: Captioning Not Required

XII. Remediation:If a member of the GRCC Community is found to not be in compliance with the Audiovisual Captioning Policy, The Director of Accessibility will then contact and work with faculty and/or any contracted media company in conjunction with the Media Department in a timely manner to bring media into compliance.

When audiovisual media cannot be made accessible in a timely manner, the individual(s) found to not be in compliance will be responsible for providing alternative access to the information immediately. The Director of Accessibility will follow up with the content owner(s) of the media to ensure understanding of the policy and proper training is administered, so future issues of this nature do not occur.

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• This policy is about compliance with a federal mandate to provide

access to equal and effective communication for all students, staff, and community members.

• The purpose of this policy is not to penalize faculty members. The purpose is to make the campus community aware of our responsibility, resources available to address shortcomings and appropriate courses of action to take in select scenarios.

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

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

– (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)

SEEKING A VOTE TODAY

1. The Audiovisual Captioning Policy Committee is seeking a vote.

Feedback/Questions: