Addressing Accessibility Issues in Healthcare Education
Questions of accessibility have become increasingly more visible in healthcare education. For healthcare education programs, providing access to instructional materials and/or Information and Communication Technology (ICT) has become a necessary part of creating a program that serves all members of a learning community. Meeting accessibility standards is necessary to comply with federal law, and it also improves outcomes for everyone, whether they have a disability or not. This also means that education and training programs need to choose their software vendors carefully.
Video Recording platforms like VALT from Intelligent Video Solutions have been developed according to WCAG 2.0 standards helps programs remain complaint. Today, Mary Hoppe BSN RN, Director of Healthcare Simulation at Intelligent Video Solutions sheds some important light at some of the key evidence regarding accessibility issues in Healthcare Education for disabled learners.
People with disabilities are more common than many realize. Many students, faculty, staff, and clinical subjects have a disability. According to the Department of Education, 9.0% of students under 23 have a disability, a number that dramatically increases with age to 15.7% for those over 291. These disabilities include visual impairments, deafness or being hard of hearing, speech impairments, mobility issues, and more; some students face multiple such disabilities. Learning outcomes for disabled students include greater challenges, and a lack of accessibility can increase a student’s difficult interacting with materials and completing work, leading to a raised risk of matriculation and completion failure2. A strong healthcare education program can best serve students, faculty and staff by maintaining high accessibility standards.
As the world continues to become more digitized, healthcare education programs and other institutions of higher learning have more tools than ever to make knowledge accessible to disabled students3. Associations like the AACN have published tool kits to help Accommodate Students with Disabilities to help their member Nursing and Simulation programs navigate this landscape. However, unless actively guarded against, students with disabilities still have access barriers to web and ICT resources, a problem that has results in numerous lawsuits and compliance reviews, including one currently face by Harvard and the Massachusetts Institute of Technology4. In one typical such case from 2015, the alleged discrimination due to a lack of accessibility resulted in a $40,000 settlement from one higher education institution, and a requirement for them to adhere to the following guidelines5:
- Requiring the completion of an accessibility audit for a subset of ICT resources within six months;
- Third-party verification that all such resources are accessible before contract execution;
- Requiring that procurement of all such resources meet WCAG 2.0 AA and Section 508 standards;
- Prohibiting courses from requiring the use of instructional resources that do not meet WCAG 2.0 AA guidelines (or have not been reviewed by an accessibility auditor);
- Requiring all faculty to prepare a full list of required instructional materials at least three weeks prior to the beginning of a class.
In the absence of clear accessibility policies, many healthcare educations programs engage in ad hoc solutions for ICT accommodation, inadvertently creating additional barriers of equal access for those with disabilities. This article addresses this problem for healthcare education programs and provides an overview of best practices and standards in personnel, polices, and processes to support accessibility in ICT6.
Accessibility requirement for healthcare education programs are currently governed under the same auspices that affect other institutions of higher learning. A 2010 joint letter from the US Department of Justice and the US Department of Education Office for Civil Rights was sent to all university and college presidents to remind them of their technology accessibility non-discrimination obligations. This letter informed higher learning institutions that not affording students with disabilities the same opportunity to participate in a manner afforded to others is a violation of Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act. The letter made clear that technology access must be addressed for students with disabilities: “It is unacceptable for universities to use emerging technology without insisting that this technology be accessible for all students.”7
In the eight years since that publication, numerous institutions have face lawsuits or undergone compliance reviews for inaccessible ICT products8, so the stakes can be high. For healthcare education programs, the most important challenge is learning how to purchase, use, and develop ICT products while meeting the guidelines for individuals with disabilities. To succeed, there are three things healthcare education programs should do: designate a role responsible for technology accessibility issues, actively manage the implementation of accessibility standards, and maintain awareness of the liabilities related to technology access.
What is ICT Accessibility?
Title II of the Americans with Disabilities Act requires that public entities provide the opportunity to full and equal enjoyment of services to individuals with disabilities and that those people not “be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity”9. In a healthcare education program, this includes any ICT systems and products. The term ‘accessible’ has been defined as, “a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use”, while also acknowledging that ‘accessible’ is not always the same as “identical ease of use”10. Practically, this means that healthcare education programs are expected to ensure equal opportunity to the services and benefits provided from ICT systems and products.
Since 2017, healthcare education programs, like all programs in institutions of higher learning, are recommended to adhere to a minimum standard defined by the Web Content Accessibility Guidelines 2.0, Level AA (WCAG 2.0 AA). WCAG 2.0 AA is an international standard for ICT accessibility11, based on four principles for ensuring Internet-based content is accessible to individuals with disabilities. Products should be perceivable, operable, understandable, and robust. As a set of principles rather than specific rules, WCAG 2.0 allows a greater degree of flexibility for designers and developers to support access for individuals with disabilities, which allows these guidelines to continue to maintain relevance as technology changes, as well as be applicable to all ICT products. These principles form a framework for creating accessible content and technology.
From lowest to highest, there are three levels of specific, testable success criteria in the WCAG 2.0 guidelines: A, AA, and AAA. To be rated at the AA level requires accessibility success criteria that are essential, can be reasonably achieved, and are appropriate to all types of content (a level that forms the basis for the US Section 508 Standards)12.
For healthcare education programs, ICT accessibility is associated with its personnel, policies, and processes.
Personnel: Having faculty, staff, and administrators who are unfamiliar with accessibility requirements is a common way that healthcare education programs open the door to litigation through the unknowing creation of access barriers for disabled students. Common decisions made in instruction, such as not considering the accessibility of materials or technology, can result in limited participation for students with disabilities and otherwise jeopardize their academic progress. An accessibility coordinator can help faculty, staff, and administrators create a healthcare education program free of access issues or barriers13. Solutions that make products and instruction more accessible help everyone, and are evidence of thorough, thoughtful design14.
Policies: Having a well-defined and understandable board policy is critical to forming a set of expectations and creating a framework that can inform future decisions. Documented accessibility standards will serve faculty, staff, and administrators as a guideline for the development of content or the procurement of technology. Clearly identifying the minimum accessibility standard is crucial in reducing the risk of creating access barriers for students with disabilities (even inadvertently) and failing to be ADA compliant.
These accessibility issues extend beyond students. Faculty, staff, and administrators may also have accessibility needs. During the hiring process, applicants seeking employment within a healthcare education program find the website inaccessible, putting that program in jeopardy of violating Title I of the ADA. Certain ICT accessibility standards may be necessary for technology that is utilized in relation to clinic subjects. ICT accessibility standards should be understood to include products and systems for everyone who might interact with a healthcare education program.
Processes: To maximize access for students and to minimize the risk of litigation, healthcare education programs should include procurement and grievance processes related to ICT accessibility. It is essential that those who encounter an ICT accessibility issue have the opportunity to provide feedback; a key aspect to accomplish this is having a formal, documented process to address and resolve any accessibility issues, including a grievance process with an expected response time and an appropriate contact person.
Healthcare education programs also need to pay special attention to procurement. The institutional process during this step needs to determine whether ICT resources, software, web applications, and content meet the accessibility standards set in policy. Reviewing a product’s accessibility can include numerous steps, such as informing a vendor of minimum accessibility standards the clinic education program requires of ICT, including accessibility requirements in contracts, and obtaining accessibility documentation of a product. Failure to initiate these processes during purchasing can result in a significant risk of major access barriers for those with disabilities. Creating a procurement process that includes accessibility checks can ensure that ICT products don’t exclude users and limit opportunities for participation, can protect the institution from legal challenges, and can prevent waste with the inevitable purchase of a new ICT product that does offer accessibility.
Since 2010, a clear consensus of best practices has emerged for creating an accessible ICT environment in education institutions. Informed by compliance reviews, settlement agreements, lawsuits, and expert evaluation, the follow guidelines outline the best practices for personnel, policies, and processes that increase ICT accessibility while mitigating liability.
- Designate an ICT accessibility coordinator
- Train all faculty, staff, and administrators in accessibility issues
- Create a board policy that affirms a commitment to accessibility
- Establish an ICT accessibility policy that ensures compliance with WCAG 2.0 AA standards
- Require all instructional materials, technology, and web content meet WCAG 2.0 AA standards
- Review all ICT resources, policies, and procedures related to disability services with a third party or consultant
- Ensure that procurement processes include reviews of the accessibility of ICT products and inform vendors they are expected to meet WCAG 2.0 AA standards
- Perform periodic audits of ICT products using both automated and manual evaluation tools
- Create a clear grievance process that is easily available online
When it comes to accessibility expectations and standards, the stakes have raised for all of higher education. Responsible leaders in healthcare education programs need to institute appropriate ICT accessibility to ensure the opportunities of students with disabilities as well as to protect their institutions from legal action. Engaging in ICT accessibility best practices for personnel, policies, and processes will help meet the diverse needs within a healthcare education program, contributing to the growth of those with disabilities as well as everyone else.
Learn More About VALT from Intelligent Video Solutions which is ICT Compliant!
- "Digest of Education Statistics: 2015." Department of Education, National Center for Education Statistics, 2016, https://nces.ed.gov/programs/digest/d15/ch_3.asp
- Brand, B., Valent, A., Danielson, L. "Improving College and Career Readiness for Students with Disabilities." College and Career Readiness & Success Center, American Institutes for Research. 2013.
- Snively, E. "New NC State IT Accessibility Coordinator Emphasize Outreach." Office for Institutional Equity and Diversity, North Carolina State University, 17 Nov. 2017, https://oied.ncsu.edu/divweb/2017/11/17/new-nc-state-it-accessibility-coordinator-emphasizes-outreach/
- "Higher Education Lawsuits." California State University Chico Accessible Technology Initiative, 2016, https://www.csuchico.edu/ati/lawsuits.shtml
- "Settlement Agreement and Release between Siskiyou Joint Community College District and Student." TRE Legal Practice, 2 Sept. 2015, https://www.trelegal.com/wp-content/uploads/2016/10/Public-Fully-Executed-Redacted-COS-Settlement-Agreement.pdf
- "Accessible Instructional Materials in Higher Education Act (S. 2138/H.R. 1772)" National Federation of the Blind, 2017, https://nfb.org/aimhighfactsheet
- "Joint ‘Dear Colleague’ Letter: Electronic Book Reader." Civic Rights Division, U.S. Department of Justice and Office for Civil Rights, U.S. Department of Education, 29 June 2010, https://www2.ed.gov/about/offices/list/ocr/letters/colleague-20100629.html
- "Resolution Agreements and Lawsuits." University of Washington, 2017, https://www.washington.edu/accessibility/requirements/accessibility-cases-and-settlement-agreements/
- Americans with Disabilities Act, Title II U.S.C. § 35.130 (2016).
- "Resolution Agreement South Carolina Technical College System OCR Compliance Review No. 11-11-6002" U.S. Department of Education, 28 Feb. 2013, https://www2.ed.gov/about/offices/list/ocr/docs/investigations/11116002-b.pdf
- "Nondiscrimination on the Basis of Disability; Accessibility of Web Information and Services of State and Local Government Entities." Civil Rights Division, Department of Justice, 2016, https://www.ada.gov/regs2016/sanprm.html
- Eggert, E. and Abou-Zahra, S. "How to Meet WCAG 2.0" Version 2.1.1. W3C Web Accessibility Initiative, 16 Sep. 2016, https://www.w3.org/WAI/WCAG20/quickref/
- Zirkle, K. and Bond, L. "The Anatomy of an IT Accessibility Coordinator." Online Learning Consortium, 26 May 2016, https://www.3playmedia.com/resources/recorded-webinars/the-anatomy-of-an-it-accessibility-coordinator/
- Levine, M. "Tech Accessibility Efforts Ramp Up With New Coordinator." University Times, University of Pittsburgh, 10 May 2018, https://www.utimes.pitt.edu/news/tech-accessibility