The latest regulatory change affecting HE hasn’t come from the Office for Students – it came from the Cabinet Office. On 23 September, the government brought the EU Web Accessibility Directive into law with a statutory instrument.
Policy Connect has worked with the All-Party Parliamentary Group for Assistive Technology to report on what the rule change means for universities and disabled students.
In the report‘s foreword, co-chairs Lord Chris Holmes and Seema Malhotra reflected that:
Providing a variety of learning tools suitable for all students – whether disabled or not – will allow us to both close the attainment and disability employment gap and provide all students with a better opportunity to succeed in education and work.
The first aim was to illustrate what the regulations require of universities. HE sometimes seems to occupy a space in between the public and private sectors but the definition of public sector bodies in the directive squarely includes universities.
Virtual learning environments (VLEs), online course documents, and video recordings of lectures are all counted as web content – and as such has to meet an accessibility requirement. This is a technical standard for designing web content so that it is perceivable, operable, understandable, and robust – the four principles of accessible web design. What’s more, each VLE will need to include an accessibility statement, a public declaration of where the website stands on compliance and what students can do to notify the university of any inaccessible content.
The best accessibility statements will also direct students to tools to help them make best use of the VLE – for example browser plugins for reading text out loud or changing the font size. Meeting an accessibility standard, and publishing an accessibility statement, has long been recognised as good practice. Now this practice is to become a legal duty.
More useable content
I call it the “scrunched hand of doom”. You go to select a choice quote in a PDF and the cursor-hand scrunches into a fist to reveal that the whole document is just a scan. Despite all the advances in blended learning, online course materials can still be hard or even impossible to work with. For disabled students, inaccessible course content can make the VLE a barrier to learning more than an aid.
One visually impaired law student who gave evidence to our report simply said: “Documents that are uploaded onto the VLE are usually intended for sighted users”.
But learning resources can be designed to work for all students, and this approach benefits non-disabled students as well. For example, accessible content is also mobile-friendly content, something that all students increasingly expect. Digital accessibility isn’t a special adjustment for some – it goes to the heart of good teaching in modern HE.
This is why the new public sector accessibility regulations matter so much. For HE providers, online content is part of teaching and learning itself – it helps to add value to their service in a competitive market. This magnifies both the challenge and the opportunities presented by the new requirements.
Meeting the challenge
VLEs are a collaborative creation involving staff across the whole university. Teaching staff are now web content creators -whenever they upload lecture slides, or an assessment guidance document, or an article from the reading list, they are publishing to a public sector website.
But the skills involved here are far from overly technical: something as simple as adding heading styles in a Word document, or choosing colours with good contrasts for lecture slides, can make that document accessible. The challenge comes rather from the sheer number of staff who need to be made aware of these requirements and given training to improve how they make documents.
In our report, sponsored by Blackboard Ally, we recommended a cascading approach. Government should work with sector organisations to provide training for key staff such as learning technologists, who can in turn train and produce guidance for teaching staff.
This model already exists at a smaller scale. Jisc has worked with the University of Kent on the OPERA (Opportunity, Productivity, Engagement, Reducing barriers, Achievement) project to bring accessibility into the mainstream. A key element of this project, and others that we looked at for the report, was assembling a working group with representatives from across the institution, including leadership and students themselves.
It’s also important for universities to be able to share practice with one another to collaborate – e.g. on how to write an Accessibility Statement that is useful for students. Here, again, Government can play a role in providing an online platform to enable this corporation within the sector (Jisc has already set up a mailing list for those who want to keep updated on the regulations, for instance).
Inclusive teaching and learning – sometimes called universal design for learning – is educational practice that removes the barriers faced by disabled students and thereby benefits all students. It’s an approach that has gained ground partly due to cuts to Disabled Students Allowances and partly because of the wider focus on teaching within HE. The Department for Education published an independent report on inclusive practice last year and this was followed by an HEFCE study on ‘Models of support for students with disabilities’. The OfS directed providers to consider both reports in its advice on making an Access and Participation Plan.
The new regulations fit perfectly into the inclusive practice framework.
Digital accessibility has to be improved at the institutional level, rather than with individual adjustments. Disabled students can be provided with accessible content on an ad hoc basis but this undermines the goal of independent learning, overwhelms staff resources, and leaves disabled students always a step behind their peers.
The regulations set out clear obligations for universities. Ever since the cuts to Disabled Students Allowances, the sector has called for more guidance on support for disabled students, and while the reports mentioned above have been welcomed the regulations provide much greater detail on what is required. The OfS is planning a second review of provision for disabled students next year – we have recommended that the OfS uses this review to assess the sector’s progress toward compliance with the regulations.
Digital accessibility is a particularly strong example of the universal benefits of inclusive practice. For our inquiry, we heard how students are taking advantage of more usable and flexible learning resources, listening to course content read out to them as a podcast while traveling on the bus, or using heading styles to go straight to the important part of the course handbook, or re-watching a lecture with subtitles to help concentrate. An inclusive approach allows all students to learn in the ways that suit them best.
If the sector can respond effectively to these regulations, all students, disabled and non-disabled, will benefit from a better learning experience.