(as of April 30, 2019)
Commitment to Accessibility
The University of Hawaii (“UH”) is committed to ensuring that campus computing and information resources are accessible to students, faculty, staff, and visitors who have disabilities. Accessibility of our services has been a longstanding requirement under Section 504 of the Rehabilitation Act of 1973, and Title II of the Americans with Disabilities Act of 1990; web accessibility standards are newer, but part of our accessibility obligations and commitment. Ensuring equal and effective electronic and information technology access is the responsibility of all University administrators, faculty, and staff.
On May 15, 2018, UH entered into a voluntary resolution agreement (VRA) with the Office for Civil Rights (OCR) of the U.S. Department of Education. The full text of the VRA is available at https://www.hawaii.edu/access/resources/uhvra/. Additional information relating to UH compliance efforts, including current guidelines and available tools, are available at https://www.hawaii.edu/access/. Under the VRA, UH must establish a plan to ensure all new online content and functionality developed, procured, or used will be fully accessible to individuals with disabilities. In addition, by May 3, 2021, UH will take all actions necessary to ensure that individuals with disabilities have an equal opportunity to participate in the University’s programs and activities offered through the University’s website or equally effective alternate access.
This Plan for New Online Content and Functionality describes the requirements and responsibilities of UH programs and units necessary to comply with the terms of the VRA. Implementation of the plan, along with clarification of the requirements of the plan, are the responsibility of UH Information Technology Services (ITS), and the Office of the Vice President for Information Technology and Chief Information Officer (OVPIT).
Accessible: Refers to the concept that people with disabilities are able to access and use a product or system, including with the help of assistive technologies. For example, an “accessible” Web site may be designed so that the text can be enlarged by the user, rather than having a fixed font size, or may be designed so that it can be interpreted and “read out loud” by screen reader software used by those who are blind or have low-vision.
Accessible Information Technology: Information technology that has been designed, developed, or procured to be usable by, and therefore accessible to people with disabilities, including those who use assistive technologies.
Assistive Technologies: Adaptive, rehabilitative devices that promote greater independence for individuals with disabilities by changing how these individuals interact with technology. Examples include special input devices (e.g., head or foot mouse, puff and-sip switches, speech recognition), screen-reading software, and screen magnifiers.
Disability: Disability is defined as a physical or mental impairment that substantially limits one or more major life activities.
Electronic and Information Technology (EIT): EIT includes information technology and any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, the internet and intranet websites, content delivered in digital form, electronic books and electronic book reading systems, search engines and databases, learning management systems, classroom technology and multimedia, personal response systems (“clickers”), and office equipment such as classroom podiums, copiers and fax machines. EIT additionally includes any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, creation, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. This term includes telecommunication products (such as telephones), information kiosks, Automated Teller Machines (ATMs) transaction machines, computers, ancillary equipment, software, firmware and similar procedures, services (including support services), and related resources.
Equally Effective: Means that the alternative format or medium communicates the same information in as timely a fashion as does the original format or medium.
Usability: Refers to how easily, effectively, and efficiently users can use a product or system to achieve their goals, and how satisfied they are with the experience.
Website Template: A website template is a premade webpage — or set of webpages — that can be customized with images, videos and other style elements to create a complete website. Often created by web developers, the template includes everything needed (i.e. HTML, CSS, Images, and any other code required) for it to function and are developed in a single location and used in multiple places throughout the website.
Types of Disabilities
Various types of disabilities, both visible and invisible, exist in 15 to 20% of the world’s population. To create an inclusive technology experience for all users, it is helpful to understand some of the ways in which persons with different disabilities are able to access web content.
Hearing (Deafness and Hard-of-Hearing): One of the ways users who have hearing loss can use the web is if captions are provided for multimedia content (any video content that also has audio) and transcripts for audio-only content.
Visual (Blindness and Low Vision): Users with vision loss can rely on screen enlargement, keyboard-only navigation, and/or the use of screen reader technology. Access to information via these means is dependent on sizable fonts, good color contrast, and well-structured websites that label all elements properly.
Motor (Physical Difficulties): Some users with physical difficulties are likely to use only a mouse, only a keyboard, voice or other inputs to control and navigate the web. Websites developed with the flexibility of input options are more accessible to these individuals.
Cognitive: Users with cognitive impairment rely on consistent navigation structure. Overly complex presentation, flickering, or strobing designs can be confusing to this group of users, and may trigger other symptoms or adverse reactions.
Applicable Federal Law
This Plan for New Online Content and Functionality is constructed based on federal civil rights laws, specifically Section 504 of the Rehabilitation Act of 1973 (Section 504), and the Americans with Disabilities Act of 1990 (ADA). Section 504 prohibits discrimination on the basis of disability in programs and activities receiving financial assistance from the federal government. ADA prohibits discrimination on the basis of disability by public entities (Title II). Both Section 504 and the ADA require that UH provide equal opportunity to individuals with disabilities to participate in, and receive the benefits of, the educational program, and require that the University provide accommodation or modifications when necessary to ensure equal treatment.
When both of these laws were passed, information technologies had not yet attained the prevalence that it now has throughout society, including education, and neither law explicitly mentions information technology accessibility. The Office of Civil Rights has issued guidance around its long-standing nondiscrimination requirements that schools use technology to provide educational benefits, services, or opportunities, such technology must be fully accessible to students with disabilities. Although accommodations or modifications can also be made to ensure equal access, these accommodations must ensure that the benefits of the educational program are provided to users in an equally effective and equally integrated manner. Further guidance on the definition of information technology accessibility is also available in the Section 508 standards or W3C Web Content Accessibility Guidelines.
The U.S. Department of Justice (DOJ) has proposed new rules that would explicitly define the requirements for web accessibility under the ADA. An announcement regarding these new rules was expected from the DOJ in 2013, but to date none have been issued.
Scope of the Plan for New Online Content and Functionality
This scope of this plan includes the following:
Web: All websites and web-based software published or hosted by UH or used to conduct UH business (including remotely hosted sites and software) must meet the requirements of this plan and indicate in plain text a method of contact for Persons with Disabilities having trouble accessing content.
Instructional Materials: All electronic instructional materials, optional and required, must be Accessible. This includes, but is not limited to, syllabi, textbooks, presentations and handouts delivered as online content.
Documents: All UH produced, maintained or distributed electronic documents must be Accessible. This includes, but is not limited to, word processing documents, PDFs, presentations, publications and spreadsheets that are scanned, uploaded, posted or otherwise published or distributed electronically.
Electronic Media: All electronic multimedia resources used by UH for instruction, communication, marketing, promotion or other academic or business purposes must be Accessible. Video must be closed-captioned and audio-described and audio resources must be transcribed.
Procurement: The procurement of products and services that create, maintain or deliver online content shall include the requirement that products and services adhere to the applicable Federal statues and requirements cited in this plan.
Requirements of UH Programs and Units Under the Plan for New Online Content and Functionality
In order to achieve the necessary compliance under the VRA, with the objective of being able to report satisfaction of the requirements under the VRA by May 3, 2021, UH will require that all new online content and functionality developed in accord with the following best practices:
- Implementation and adherence to World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 level AA;
- Purchase, development and use of hardware and software products that support universal design and access; and
- Application of accessibility tools and techniques in the creation of digital materials and communications. For example, text-based alternatives which may include:
- Alternative text descriptions for images
- Transcripts for audio content
- Captioning and audio description for multimedia.
In cases where Web content, Web applications, digital materials or services are not accessible, an individual with a disability may request that the Web content, Web application, digital material or service be made available in an accessible alternative format or that an equally effective accommodation be provided by the unit responsible for its provision and maintenance. The responsible unit must, upon receipt of the request, make accessible versions available to all users within a reasonable time period.
Certain online content or functionality may be exempted from these accessibility requirements under the following conditions:
- Action(s) to make the online content or functionality fully accessible would fundamentally alter or damage the online content or functionality;
- Action(s) to make the online content or functionality fully accessible would cause an undue financial or administrative burden; or
- Content created and last made available prior to January 1, 2015, provided that such content is historical in nature, and no longer used nor accessed.
If any of the exemptions apply, the responsible program or unit administrator, or its representative, shall consult with OVPIT to obtain approval by OVPIT of the requested exemption. Program or unit administrators are reminded that the program or unit remains responsible to ensure that to the maximum extent possible, individuals with disabilities shall receive the benefits or services that are provided by the subject online content or functionality.
Individual web pages published by students or non-UH organizations hosted by UH but that do not deliver or support UH-related services are outside the scope of these requirements.
Responsibilities Under This Plan for New Online Content and Functionality
Programs and Units
- Ensure compliance with this plan.
- Ensure that departmentally owned or managed classrooms and labs are equipped with IT resources that are capable of delivering Accessible Electronic Information, Communication and Technology and are compatible with assistive technology.
- Ensure that all hardware, software, applications, systems, video and multimedia purchased or developed are Accessible and, as applicable, compatible with assistive technology.
- For each campus or program/unit with significant online presence, register one or more lead technical resource(s) as a SiteImprove administrator to support compliance monitoring activity.
- Promptly, upon request by a Person with a Disability, provide content, in an Accessible format, or ensure that to the maximum extent possible, that the requestor receives the benefits or services that are provided by the subject content.
- Consult with OVPIT regarding interpretation of this plan, and any requests for approval (by OVPIT) of any exceptions under this plan.
Office of the Vice President for Information Technology and Chief Information Officer (OVPIT)
- Administer and interpret this plan.
- At least annually, review and make necessary revisions to this plan as required by regulatory and technological changes.
- Provide tools, training and assistance to Programs and Units to aid in their ability to comply with this plan.
- Establish and maintain a catalog of resources and content to support efforts by UH programs and units, to include a broad range of example techniques for diagnosing and remediating online content.
- Conduct regular outreach and general training sessions to ensure broad knowledge of and access to tools, training and assistance.
- Monitor institutional compliance via consolidation of SiteImprove metrics and reports, along with other efforts as deemed appropriate.
- Promote awareness of the requirements under the VRA and this plan, and widely encourage programs and units to achieve appropriate levels of compliance.
- Review and approve requests for exemptions under this plan.
Equal Employment Opportunity and Affirmative Action Office (EEO/AA)
- Receive and process complaints and violations as reported.
Each program and unit will develop its own priorities and action plans to achieve the objectives of this plan, considering factors such as feasibility, funding, technical capacity and staff training needs. Priority should be given to creating accessible web pages and resources for core institutional information and services, such as the main campus/program/unit website, admissions, student services, and instructional delivery.
The following priorities are suggested as a starting point:
- Engage with ITS to ensure familiarity with tools, techniques and assistance available to all UH programs and units.
- All new or revised web pages and other digital media resources (e.g., newsletter, campus announcements, etc.) published, hosted, provided by or otherwise representing the university should be made accessible at the time of creation or revision.
- The top 20% of existing web pages and resources most frequently used (e.g., that get the largest number of hits) are a top priority for review and remediation.
- “Critical path” applications or functions (e.g., Admissions and Records, student services and employee policies and benefits, etc.) should be also placed in the first priority for review and remediation. These should be identified in consultation with knowledgeable members of the campus/program/unit community.
- Pages and resources required for participation, funding, disability-related services and other key information or functions needed by people with disabilities, not already in the top 20% should be reviewed and remediated.
- Develop a corrective action plan based on priorities, feasibility and resources.
- Develop and prominently post a procedure for reporting complaints of web and technology accessibility barriers.
- All new videos must include effective captioning of content.
- Any remaining pages and resources providing core institutional information and/or functions should be reviewed and made accessible in accordance with the campus/program/unit plan.
- Provide training to all levels of faculty and staff who modify websites or use information and communication technology in their instruction (e.g. how to prepare accessible PDF and Word files).
- Review electronic equipment that serves the general community (e.g. information kiosks, public use library terminals, security call boxes, ATMs, etc.).
- Schedule and conduct regular accessibility reviews of electronic and information technology.
- All other web pages and resources should be reviewed and included in the action plan.
- Include ADA accessibility knowledge and skills as a “Desirable Qualification” in information technology, communications and related job descriptions.
- Encourage faculty members to cover accessible design in their curriculum.
Programs and units may consult with OVPIT and ITS as resources to provide advice in the preparation of plans and prioritization of work.
Complaints and Reporting Violations
Any complaints related to compliance with this plan, the applicable federal statutes, or any UH unit or program, may be directed to the Equal Employment Opportunity and Affirmative Action (EEO/AA) Office. Additional information, including complaint procedures, is available at the EEO/AA website, https://www.hawaii.edu/offices/eeo/.
Violations of the requirements in this plan may be reported to the appropriate campus or system contacts in the following table (also at https://www.hawaii.edu/offices/eeo/ada-504-coordinators/). Remediation of violations may include removal of the subject content until such time as the content is compliant with the requirements of this plan.
|Contact Name, Title||Phone Number|
|UHM-Students||Lori Ideta, VCS
Ann Ito, KOKUA
|UHM-Employees||Mark Au, EEO/AAemail@example.com|
University Disability Services
|UHH-Employees||Jennifer Stotter, EEO/AAfirstname.lastname@example.org|
Center for Student Access
|Hawaii CC-Students||Mari Giel,
|Hawaii CC-Employees||Mari Chang,
|Honolulu CC-Students||Wayne Sunahara,
|Honolulu CC-Employees||Monique Tingkang,
|Kapiolani CC-Students||Deneen Kawamoto,
|Kapiolani CC-Employees||Kelli Brandvold,
|Kauai CC-Students||Marilyn Hashisaka,
|Kauai CC-Employees||Teresa Tumbaga,
|Leeward CC-Students||Kris Hernandez,
|Leeward CC-Employees||Kay Ono,
|Maui College-Students||Catherine Taylor,
|Maui College-Employees||Susan Tokunaga,
|Windward CC||Ann Lemkeemail@example.com|
|CC System||Mary Perreirafirstname.lastname@example.org|
|UH System||Mark Au, EEO/AAemail@example.com|
|Clarify Compliance Requirements and
|ITS ADA Support
Garret Yoshimi, VPIT