Portland Community College | Portland, Oregon

What are the responsibilities of Portland Community College (“PCC”) in ensuring that online courses are accessible?  What role do departments, instructors, administrators, and employees play in carrying out those responsibilities?

PCC has an obligation to comply with the Americans With Disabilities Act (the “ADA”), Section504 of the Rehabilitation Act, and Oregon laws addressing disability discrimination and accommodations.  These laws prohibit disability discrimination, which may include failing to make reasonable modifications and accommodations for eligible individuals with disabilities.  All PCC operations are subject to the nondiscrimination requirements of these laws.  Thus, all administrators, instructors, and employees must comply with the requirements.

Disability laws require PCC to make its educational environment equally accessible to all students.  PCC, through its administrators and employees, is required to make PCC technology accessible to individuals with disabilities.  Making technology “accessible” means that individuals with disabilities are enabled to independently acquire the same information, engage in substantially the same interactions, and enjoy the same services within the same time frame as individuals without disabilities, with substantially equivalent ease of use.  If a particular educational component (such as a tool, text, instructional material, or other resource) is not equally accessible to all students, PCC must either refrain from using the inaccessible component or be able to provide reasonable accommodations or modifications that permit individuals with disabilities to receive all the educational benefits provided by the component in an equally effective and equally integrated manner.

Employees, instructors, and administrators all have a role to play in ensuring accessibility for PCC students.  Please refer to “Who’s Responsible for Accessibility of Online Courses” to get a general idea of the various responsibilities held by each individual and department with regard to online accessibility.

What are the PCC Accessibility Guidelines for Online Course Content, and to what do they apply?

PCC Accessibility Guidelines for Online Course Content provides information about making course content accessible. The laws requiring accessibility apply to all PCC courses, not just Online Learning courses.

PCC currently follows the Web Content Accessibility Guidelines 2.0 (“WCAG 2.0”) for making Web content accessible to a wide range of people with disabilities.  Because federal or state disability laws do not specify a particular set of guidelines for ensuring that online materials are accessible, PCC has chosen to strive for compliance with WCAG 2.0, which is internationally recognized as the standard for website accessibility.  This standard is often referred to by the United States Department of Education’s Office for Civil Rights (the “OCR”) for evaluating an institution of higher education’s level of online accessibility.

Which WCAG 2.0 standard is PCC using and why?

PCC is working toward WCAG 2.0 Level AA compliance. WCAG 2.0 Level AA ensures a very good level of accessibility. Websites conforming to Level AA will be accessible for most people, under most circumstances, with most technologies they use. WCAG 2.0 Level AA is also a preferable standard compared to WCAG 2.0 Level A, the next level down, because while Level A sets a minimum level of accessibility that eliminates the major accessibility barriers, it does not necessarily achieve the desirable level of accessibility for reaching more individuals with disabilities.

What is PCC’s level of risk when it comes to the accessibility of online course content?

If PCC or any of its employees do not comply with the federal or state laws prohibiting disability discrimination, PCC could be vulnerable to sanctions from the OCR or other legal claims. For instance, if a part-time instructor denies an eligible student an equal opportunity to participate in a course by utilizing inaccessible course content and fails to provide a reasonable accommodation that provides the same information in an equally effective and equally integrated manner, PCC may be held legally responsible for the instructor’s actions.

What is my personal liability as an instructor at PCC?

PCC prohibits unlawful discrimination, harassment, and retaliation, and requires its instructors and staff to comply with its Nondiscrimination and Non-harassment Policy at all times. Even if an employee is in compliance with PCC policy and applicable disability laws, the employee could still be named in a lawsuit or administrative complaint for allegedly discriminating against an individual with a disability by failing to make a course or a component of the course sufficiently accessible. In such a case, PCC has a duty to, will provide a defense, and pay an award for an employee if PCC determines that: (1) the alleged illegal act or failure to act occurred in the performance of the individual’s duties as a PCC employee, and (2) the employee has not engaged in malfeasance or willful or wanton neglect of duty.

How do I check my course accessibility?

Check your content against the PCC Accessibility Guidelines for Online Course Content checklists. If your content doesn’t meet a certain checked item, consult the how-to instructions built into the checklist.

Consult with onlineaccess@pcc.edu or Accessible Ed & Disability Resources if you are unsure whether your content is accessible or if you need help coming up with accessible alternatives.

What if some of my course content isn’t accessible?

Ordinarily, you do not need to remove inaccessible content if you provide an equally effective alternative that is accessible.

Consult with onlineaccess@pcc.edu< or Accessible Ed & Disability Resources if you are unsure whether your content is accessible or if you need help coming up with accessible alternatives.

If I want to use interactive learning objects in my class, how do I determine whether they are accessible?

If you are using a tool that requires keyboard or mouse input from the student, contact onlineaccess@pcc.edu to get that tool tested for accessibility. For example, publisher homework websites should be tested for accessibility.

How do we ensure that we can timely meet the captioned video accommodation need of a student with a disability?

If an eligible student requests video captioning as an accommodation for a course, PCC must provide the video captioning or another accommodation or modification that enables the student to receive all the educational benefits of the video in an equally effective and equally integrated manner. To be prepared for video captioning requests, PCC encourages instructors to begin each term with captioned videos whenever possible. An instructor can accomplish this by searching for and selecting only third party videos that are already captioned and captioning their own videos as soon as they are created. In some instances, however, it might not be practical to caption all videos before the beginning of the term. In those cases, PCC’s approach to captioning is as follows.

As soon as the instructor learns that one of their students has requested video captioning as an accommodation (even after the term has started), the instructor must:

1. Work with Online Learning for fully online courses and Accessible Ed & Disability Resources for all other courses, to caption all videos. PCC has the resources to caption instructor-created videos very quickly in most cases. Videos must be captioned before they are released to any student. It may be necessary to adjust the date on which a video is shown and any related coursework that is due or testing that is conducted.
2. Work with Online Learning for fully online courses and Accessible Ed & Disability Resources for all other courses, to caption all other videos. Depending on the source of the media, it may take more time to address captioning for videos or material that is not created in-house. Again, a video must be captioned before it is released to any student, and it may be necessary to adjust the date on which the video is shown and any related coursework is due or testing is conducted.
3. If, for some reason, captioning in a timely manner is not possible, either refrain from using the video or work with Accessible Ed & Disability Resources to provide reasonable accommodations or modifications that permit the student to receive all the educational benefits provided by the video in an equally effective and equally integrated manner.

If you have any questions about this process, please contact Supada Amornchat in Online Learning or Kaela Parks in Accessible Ed & Disability Resources.

If something is optional, does it have to be accessible?

Yes. Optional materials should be accessible or the instructor should be able to provide a student with an accommodation or modification that enables the student to receive all the educational benefits of the optional material in an equally effective and equally integrated manner.

Our career technical program requires good vision and hearing, so do we need to make our online materials accessible?

Yes. If the career technical program is going to be using emerging technology such as online materials for its nondisabled students, it must ensure that those materials are fully accessible or provide reasonable accommodations or modifications that enable disabled students to obtain the same benefits of the materials in an equally effective and equally integrated manner.

If we have multiple sections of a course online, can we just make one of them accessible and direct all students with disabilities to that course?

No. PCC has an obligation to make its educational environment equally accessible to all students, and this obligation encompasses course subjects and schedules. In other words, if there are four different sections of a course for which nondisabled students may register, a student with disabilities needs to be able to register for any of those four sections in order for the educational environment to be equally accessible.

How do I find resources and get training?

See the accessibility training page on pcc.edu/access.