The 504 Coordinators Role in Accessible Online Learning

Raymond Rose

Rose & Smith Associates

Port Aransas, TX

Introductions

Name

Affiliation

Role(s)

What you’re wanting to get from this session

https://doe.sd.gov/oess/documents/sped_section504_guidelines.pdf

Designate a Section 504 Coordinator

Under Section 504 of the Rehabilitation Act of 1973, each school district that receives federal financial assistance must designate at least one employee to coordinate the district’s compliance with its responsibilities under Section 504. If a district has 50 or more employees, it must also designate at least one employee to coordinate the district’s compliance with Title II of the Americans with Disabilities Act (ADA). Most school districts designate one employee to serve both of these roles. This employee is often known as the Section 504/ADA Coordinator.

http://www.k12.wa.us/Equity/pubdocs/Section504CoordinatorDescription.pdf

1. Coordinating and monitoring the district’s compliance with Section 504 and Title II of the ADA, as well as state civil rights requirements regarding discrimination and harassment based on disability;

2. 2. Overseeing prevention efforts to avoid Section 504 and ADA violations from occurring;

3. 3. Implementing the district’s discrimination complaint procedures with respect to allegations of Section 504/ADA violations, discrimination based on disability, and disability harassment; and

4. 4. Investigating complaints alleging violations of Section 504/ADA, discrimination based on disability, and disability harassment.

the Section 504/ADA Coordinator is, at a minimum, responsible for:

http://www.ada.gov/pcatoolkit/chap2toolkit.htm

is responsible for coordinating the efforts of the government entity to comply with Title II and investigating any complaints that the entity has violated Title II. The name, office address, and telephone number of the ADA Coordinator must be provided to interested persons.

the ADA Coordinator…

https://doe.sd.gov/oess/documents/sped_section504_guidelines.pdf

1. Provide written assurance of nondiscrimination whenever the school receives federal money (e.g., on the LEA application). [34 CFR § 104.5(a)]

2. Designate an employee to coordinate compliance with Section 504 (required if there are15 or more employees—recommended for all). [34 CFR § 104.7(a)]

Procedural Requirements of Section 504* Among other things, to be in compliance with Section 504, schools must do the following:

Procedural Requirements of Section 504* Among other things, to be in compliance with Section 504, schools must do the following: (continued)

3. Adopt and implement grievance procedures, which incorporate due process standards, to resolve complaints of discrimination. While providing for mediation is a best practice, developing the grievance procedures for the complaint process and due process hearings are mandatory for a recipient of federal funds that employs 15 or more persons. [34 CFR § 104.7(b)].

4. Provide notice to students and parents stating that the agency does not discriminate on the basis of disability. The notification shall identify the employee responsible for coordination compliance with Section 504 (if more than 15 employees). Notice must be included in student/parent handbook. [34 CFR §104.8]

Procedural Requirements of Section 504* Among other things, to be in compliance with Section 504, schools must do the following: (continued)

5. Identify and locate qualified children with disabilities within their jurisdiction who are not receiving a public education. [34 CFR § 104.32(a)]

6. Annually notify persons with disabilities and their parents or guardians of the school’s responsibilities under Section 504 to identify and locate every qualified child with a disability who is not receiving a public education. [34 CFR § 104.32(b)]

Procedural Requirements of Section 504* Among other things, to be in compliance with Section 504, schools must do the following: (continued)

7. Provide parents or guardians with procedural safeguards: a. Notice of their rights b. An opportunity to review relevant records c. An impartial hearing: It is important that parents or guardians be notified of their right to request a hearing regarding the identification, evaluation, or educational placement of individuals with disabilities and to be represented by counsel. [34 CFR §104.36] d. Review procedures: Compliance with the procedural safeguards under the IDEA is one way of meeting these requirements. 8. Conduct a self-evaluation of the school facilities, programs, and policies to ensure that discrimination is not taking place. [34 CFR §104.6 (c)] This study is conducted with help from interested persons, including persons with disabilities.

Association of Higher Ed and Disability

Self-evaluation Guide https://www.ahead.org/uploads/docs/resources/ada/Self_Evaluation_Model.doc

OCR’s Operational Definition

“those with a disability are able to acquire the same information and engage in the same interactions — and within the same time frame — as those without disabilities.”

OCR Compliance Review 11-11-2128, 06121583, paraphrased from 11-13-5001, 10122118, 11-11-6002

http://www.inacol.org/resource/access-and-equity-for-all-learners-in-blended-and-online-education/

Simple way to check* your website

FREE website accessibility test sites

http://CynthiaSays.com

http://WAVE.webaim.org

* Not comprehensive and will not check all accessibility issues but is a good quick check of the basic issues.

AInspector Sidebar 1.0.0-beta.1 for FireFox

WAVE Evaluation Tool for Google Chrome

Browser Based Accessibility Tools*

* Not comprehensive and will not check all accessibility issues but is a good quick check of the basic issues.

Common OCR Findings

1. Lack of Alternative Text on All Images

2. Documents Not Posted in an Accessible Format

3. Lack of Captions on All Videos and the Inability to Operate Video Controls Using Assistive Technology

4. Improperly Structured Data Tables

Common OCR Findings

5. Improperly Formatted and Labeled Form Fields

6. Improper Contrast Between Background and Foreground Colors

7. Frames Not Titled with Text that Facilitates Frame Identification and Navigation

Distance Education Accessibility Guidelines for Students with Disabilities

2011 California Community Colleges

http://extranet.cccco.edu/Portals/1/AA/DE/2011DistanceEducationAccessibilityGuidelines%20FINAL.pdf

Raymond Roseray@rose-smith.com512.791.3100

Presentation slides on this topic are available at SlideShare.net under RaymondRoseAnd at my blog: rmrose.blogspot.com