UDL On Campus: Equally Effective Alternate Access Plan (EEAAP)

What

What is this resource about? This resource provides an example of the components 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.

Why

Why is this important for higher education? Postsecondary institutions are required to comply with two federal disability civil rights statutes: Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA). Accessibility is legally mandated and is also a foundational component of UDL to create educational environments responsive to the widest possible range of learners.

Background Information

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.

Relevance

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.

Core Material

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.

Example of 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:

EEAP Components

1. Description of the issue

Describe specifically what part of the system, software, or process is a known accessibility issue and is not accessible per Section 508 and CSU ATI standards. (Information on Section 508 and ATI standards can be found at CSU Accessible Electronic and Information Technology (E&IT) Procurement.)

2. Persons or groups affected

List the person(s) or groups who may/will be affected by this issue, including the total number of affected persons. Groups may be specific (e.g., IT employees, Engineering students, etc.) or general (e.g., members of the general public, visitors, students, CSU employees, etc.).

3. Responsible person(s)

List the name(s) and title(s) of the campus employee(s) who will be responsible for providing equally effective alternate access for the specified known accessibility issue as described in Number 4.

4. How EEAA will be provided

Describe in detail how the responsible department(s)/person(s) equally effective alternate access will be communicated and what will be provided. For example, “To access room availabilities, visitors can go to a different web page that contains the same information.” Attach a separate sheet.

5. EEAA Resources Required

List any resources required (including training, equipment, additional staff, etc.) to provide equally effective alternate access for the known issue.

6. Repair Information

Include the following information in this section: Provide a brief description or any relevant information regarding repair of the issue by the vendor or third party service provider as well as the completion date.

7. Timeline for Unforeseen Events

A timeline to plan, create, implement, and follow up on accommodation for access concerns/issues that are beyond campus policy and/or outside of the realm of the questions above.

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 application?
- 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 application?
- A: Students who are blind or have low vision will be directed to a web site that has audio descriptions of molecular models.

Review

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

Equally Effective Alternate Access Plan (EEAAP)