Equally Effective Alternate Access Plan (EEAAP)
This resource discusses the development of an Equally Effective Alternate Access Plan (EEAAP) by postsecondary institutions when buying, developing, or using a technology that is not accessible to students with disabilities. An EEAAP is a plan that describes how an institution will provide alternative access to the same information or services that are delivered by inaccessible technology. This resource presents an overview of EEAAPs and provides some suggestions and examples to help institutions develop appropriate EEAAPs.
In 2010, the U.S. Departments of Education and Justice issued joint guidance to postsecondary institutions regarding the need to ensure that technology that is in place for use by students is accessible, consistent with Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA). This guidance stated that requiring the use of technology that is not accessible constitutes discrimination, unless students are given accommodations or modifications that enable them to receive the educational benefits of the technology in an “equally effective” and equally integrated manner.
Two years later, in response to a complaint brought by a blind student, the Department of Justice entered into a settlement agreement with Louisiana Tech University in which the university agreed to adopt an accessibility policy. As part of this policy, the University agreed that it would only purchase, develop, and use technology that does not exclude students who are blind or have other vision disabilities.
The agreement further stated that if it were not technically possible to make a specific technology accessible, or if to do so would require a fundamental alteration or would result in undue financial and administrative burdens, the University would develop a plan explaining how it would provide “equally effective alternate access” to the information or service delivered by the technology. The agreement explained this policy:
“Equally effective alternate access” to electronic and information technology for persons with disabilities is based on (1) timeliness of delivery, (2) accuracy of translation, and (3) delivery in a manner and medium appropriate to the disability of the person. Such alternate(s), to be equally effective, are not required to produce the identical result or level of achievement for disabled and non-disabled persons, but must afford disabled persons equal opportunity to obtain the same result, to gain the same benefit, or to reach the same level of achievement, in the most integrated setting appropriate to the person’s needs.
While the shift toward increased use of technology and digital learning materials by postsecondary institutions provides an opportunity for enhanced participation on the part of a greater number of students, the reality is that not all technologies are accessible to individuals with disabilities. It is also difficult to retrofit an inaccessible technology product.
An Equally Effective Alternate Access Plan (EEAAP) is a valuable resource that an institution can use if it is necessary to buy, develop, or use a technology that is not fully accessible. This plan describes how to provide alternate access to the same information or services offered by a less-than-accessible technology. Having an EEAAP in place for technologies that are not fully accessible will help ensure that all students will have fair and equal access in a timely manner as required by law.
When developing an EEAAP, accessibility should be considered for all parts of the educational program, including instructional materials, web sites (both academic and administrative), videos, audio files, back office products, lecture captures, web and video conferencing, learning management systems, computers, laptops, smartphones, tablets, software, apps, etc.
Creating an EEAAP
There is more than one way to create an EEAAP. Some institutions, such as California State University (CSU), have developed their own EEAAP form. CSU’s form includes the following components that describe how “equally effective alternative access” will be provided:
1. Description of the issue
2. Persons or groups affected
3. Responsible person(s)
4. How EEAA will be provided
5. EEAA Resources Required
6. Repair Information
7. Timeline for Unforeseen Events
If an institution does not have a specific form, consider including the components above in developing a document. Alternatively, a different approach that focuses more on teaching strategies and learning outcomes associated with the use of the technology may be used. For example, a form could be developed that asks faculty to check off accessibility items that should be considered in deciding whether to purchase or use a particular technology or software. The form could also include questions such as the following examples:
- Q: What are the learning outcomes desired with this mobile
- A: Student will be able to identify molecular models.
- Q: What ideas are available for alternative ways to teach
the material to a student who may not be able to use this
- A: Students who are blind or have low vision will be directed to a web site that has audio descriptions of molecular models.
This resource has addressed the following:
- What an EEAAP is
- Why it is important for postsecondary institutions to consider alternate access to technology
- How to develop an EEAAP
An EEAAP is a plan that describes how the institution will provide “equally effective alternate access” to the same information or services offered by a technology that is less than accessible.
Section 504 of the Rehabilitation Act of 1973 is a disability civil rights law that prohibits discrimination on the basis of disability in programs and activities that receive federal funding.
The Americans with Disabilities Act (ADA) is a wide-ranging civil rights law that prohibits discrimination on the basis of disability in a variety of contexts, including public and private colleges and universities.
Accommodations are adaptations provided in the classroom or on an assessment to qualifying students that do not fundamentally alter the skill that is being taught in the classroom or measured on the assessment.
Audio, in this context, is a digital form or representation of sound. It is a format that stores, copies, and produces sound according to the data in its file(s).
Video is the recording, reproducing, or broadcasting of moving visual images.