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Electronic Information Technology and Communication Accessibility (EITCA) Risk Analysis and Communication Plan

By Elias Eldayrie, VP & CIO, University of Florida And Anne L. Allen, EITCA Officer, University of Florida

Elias Eldayrie, VP & CIO, University of Florida

Universities nationwide are experiencing both lawsuits instituted by plaintiffs and audits from the Office of Civil Rights with enforcement from the Department Of Justice.  The courts have been very detailed in the relief awarded, proving the commitment to enforcement.  These judgments and decrees are not only expensive in implementation but also extremely damaging to reputations and can negatively impact funding sources.

The major areas of risk identified by the courts are a failure to:

• Allocate sufficient resources and authority to coordinate and implement the Electronic Information Technology Communication Accessibility (EITCA) Policy.
• Provide native EITCA accessibility (e.g., relying on second class EITCA alternatives for people with disabilities).
• Assign a person or entity to coordinate institution-wide accessibility.
• Provide a top-level website dedicated to accessibility.
• Provide accessible Websites.
• Provide accessible instructional materials and library resources promptly.
• Provide accurate video captioning.
• Provide accessible digital signage.
• Ensure EITC obtained, or developed by third parties is accessible.
• Implement a procedure, which ensures procured EITC is accessible, such as including accessibility requirements in RFPs and contractual language.
• Provide regular ongoing, training, instruction and support at all levels (e.g., administrators, faculty, IT staff, support staff, student employees) regarding the institution's  EITC Accessibility Policy and procedures, tools, and techniques.
• Define a technical standard for implementing EITC accessibility (such as WCAG 2.1).

The University of Florida has embarked on a campuswide consistent and comprehensive centrally-driven effort to foster diversity and expand inclusiveness through the creation of an Electronic Information Technology and Communication Accessibility Plan. The plan, grounded in UF’s conviction that electronic information and technology accessibility is a civil right of all UF stakeholders that will benefit everyone in the university community, aims to ensure that a broad population can access, benefit from and contribute to UF’s programs and services.

"Increasing diversity on campus and protecting civil rights by working toward electronic information and technology accessibility requires significant investment, but results in huge dividends for the entire university community"

Communication Plan Goals and Objectives

This plan is to increase awareness of UF’s efforts to in the area of EITCA  to achieve “native accessibility,” which is electronic information presented in a way that individuals of different abilities will have equal access without needing to request changes or accommodations as part of its ongoing educational outreach.  One major objective is also to protect the university and minimize the risk of lawsuits and audits that could result in financial penalties and potential damage to UF’s reputation.And the ultimate reason for communication ofUF’s Strategic Plan is to create an exceptional academic environment that reflects the breadth of thought essential for preeminence, achieved by a community of students, faculty, and staff who have diverse experiences and backgrounds.

UF communicates with all stakeholder groups regarding its commitment to EITCA for the entire UF community, and that EITCA is a civil right to which everyone is entitled.  Each stakeholder group is also informed of their particular role and responsibility for implementation of UF’s EITCA Policy.  The enterprise fosters visible support of diversity efforts from VPs, deans, directors, managers, and student leaders and encourages two-way communication by preparing them with tools, resources, and language to facilitate conversations.

"It is crucial the socialization of the Electronic Information Technology and Communication Accessibility policy include provided pathways for compliance and achievable goals"

Key Messages

• Electronic information and technology accessibility encompasses diversity and inclusion. It is a civil right that benefits everyone on campus and throughout the campus community.

• Access to electronic information and technology by all members of the UF community is inherent in UF’s mission as a land grant institution and as an institution is committed to supporting an electronic and information technology environment that is accessible to all, including individuals with EITCA challenges.

• An accessible EITCA environment enhances usability for everyone; by supporting EITC accessibility, the university helps ensure that a broad population can access, benefit from, and contribute to its programs and services.

• Accessible technology helps all members of the UF community participate in the mission of creating, transmitting, and preserving knowledge.

• Students with disabilities and those with diverse learning needs expect and deserve educational materials that meet the same rigorous quality standards that other students receive.

• UF adopted the World Wide Web Consortium’s standard – Web Content Accessibility Guidelines (WCAG) in creating its EITC Accessibility Policy. UF’s policy complies with federal and state laws, including the Americans with Disabilities Act of 1990 and Sections 504 and 508 of the 1973 Rehabilitation Act.

• UF’s EITCA Policy is organized around four principles, which are the foundation for users with diverse learning needs to access and use web content:

 ○Content must be perceivable to users.

 ○Interface components must be operable.

 ○Information and the operation of user interface must be understandable.

 ○Content must be robust enough to be interpreted reliably.

• UF’s efforts to achieve EITC accessibility provide the additional benefit of protecting the university against lawsuits and audits that could result in financial penalties and potential damage to UF’s reputation.

Institutions of higher education working towards EITC accessibility should begin by working through their governance structure to create and implement an initiative.  Early in the process is the adoption of an accessibility policy is essential. It is crucial the socialization of the policy include pathways for compliance and achievable goals. Steady, concerted discernable progress is has been found acceptable by the courts.  UF provides accessibility tools for the course management system, websites, and document conversion to all faculty staff and students and is funded centrally. Increasing diversity on campus and protecting civil rights by working toward electronic information and technology accessibility requires significant investment, but results in huge dividends for the entire university community.

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