What the 508 Refresh means to Public Higher Education Institutions
What does non-public facing means in the refresh? Here is the language that the federal government has included about that in the 508 refresh:
E205.3 Agency Official Communication. Electronic content that is not public facing shall conform to the accessibility requirements specified in E205.4 when such content constitutes official business and is communicated by an agency through one or more of the following:
A. An emergency notification;
B. An initial or final decision adjudicating an administrative claim or proceeding;
C. An internal or external program or policy announcement;
D. A notice of benefits, program eligibility, employment opportunity, or personnel action;
E. A formal acknowledgement of receipt;
F. A survey questionnaire;
G. A template or form;
H. Educational or training materials; or
I. Intranet content designed as a Web page.
How do we interpret that in higher education where we are trying to make education materials accessible. The fact is that the murky waters of whether or not to caption video content held within a learning management system seem to not be pronounced even with the refresh.
A Universities content is not public communication. It is a product that people have to pay for. Higher Education usually doesn’t place place course content in the public setting. The lawsuit against Harvard and MIT regards the placing of courses for public consumption. The well endowed educational institutions have a philanthropic idealism in doing this. Give the world free course! Empower humanity. The deaf did not want to be excommunicated in this idea world.
But for public schools with limited or diminishing funding, the concept of captioning every video they have on their servers is preposterous. Schools using lecture capture software can generate up to 100,000 hours of video content. At a cost of $1 to $3.25 an minute, captioning one year’s content can cost between $6,000,000 and $19.5 million.
For now a more sane approach of captioning only video content for those who have received an accommodation, verified through the disability office, makes for a practical and lucid resolution. Only the content that is publicly displayed should require to be accessible to all.
H. Educational or training materials
This section refers to internal training and educational materials that the federal government creates for federal staff. Creating content that is designed to improve or inform the workforce also needs captioning. The same is true for state government employees. That content should also have captioning. One should caption that upon request, but should have the content created with all employees in mind.
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