Accessibility for Ontarians with Disabilities Act Alliance Update
United for a Barrier-Free Society for All People with Disabilities
The AODA Alliance Calls on TVO to Take Prompt Action to Fix its Educational Web Content’s Accessibility Problems – and Other COVID Disability News
May 7, 2020
As part of its emergency plans for supporting K-12 students while schools are closed due to the COVID-19 crisis, the Ford Government announced that it has partnered with TVO, the Government-owned educational TV network. However, the AODA Alliance has revealed that there are accessibility problems with some of TVO’s educational web content. These hurt students, teachers and parents with disabilities who need accessible web content. We have called on TVO to fix this and to let us know about its plans for this.
On April 27, 2020, the AODA Alliance sent an email to TVO asking some basic questions about its efforts to ensure the accessibility of its educational web content. We set out that email below.
TVO answered us on May 5, 2020, after we had raised concerns about this issue in our May 4, 2020 virtual Town Hall event, in media interviews, and on social media. Below we set out the May 5, 2020 email we received from TVO’s digital content vice president.
We have serious concerns with TVO’s response. We described our concerns in our May 7, 2020 email to TVO’s digital content vice president, which we also set out below. We therefore ask TVO for clear answers to several specific and important questions and urge TVO to dig into this issue and get it fixed.
We also set out below an excellent news article about our May 4, 2020 virtual Town Hall. It appeared in the May 5, 2020 edition of QP Briefing. QP Briefing is an influential publication about key issues and events at Queen’s Park.
Please encourage teachers, parents, school board staff and anyone else you can to watch the archived video of the May 4, 2020 virtual Town Hall that the AODA Alliance and Ontario Autism Coalition organized. It shares practical tips on how to meet the urgent learning needs of students with disabilities during the COVID-19 crisis. Post the link on your Facebook page, on Twitter and on any other social media you use! It is https://www.youtube.com/watch?v=phdtibf5DbM
We are delighted that in under three days, our May 4, 2020 virtual Town Hall has already gotten over 800 views! We have asked the Ministry of Education to circulate this link to school boards and to post it on the Government’s Learn at Home website that shares useful resources for teachers and parents while students must learn at home due to the COVID-19 crisis.
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April 27, 2020 Email from AODA Alliance Chair David Lepofsky to TVO
ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
www.aodalliance.org Twitter: @aodaalliance
April 27, 2020
To: TVO Ontario
Via email: AskTVO@TVO.org
The Ontario Government has announced that it has partnered with TVO to provide resources to parents and teachers of school-age children who have to undertake distance learning due to the COVID-19 crisis. Resources for parents and teachers is available at https://openhouse.ilc.org/
It is vital that this educational content is fully accessible to all students with disabilities. This is especially important during the COVID-19 crisis, when students must rely on remote learning.
TVO is an emanation of the Ontario Government. The Ontario Government has said that it is leading by example on accessibility for people with disabilities and is taking an “all of government” approach to accessibility. Over one third of a million students in Ontario are students with special education needs and the vast majority of them have disabilities. As many as one of every six students in Ontario-funded schools have disabilities.
We would like to know if TVO considers all its online courses to be fully accessible to students with disabilities ? This does not simply mean that they comply with accessibility standards enacted under the Accessibility for Ontarians with Disabilities Act . Those standards in a number of ways fall short of what is required by the Ontario Human Rights Code, which guarantees equality without discrimination based on disability in areas like education. For example, the 2011 AODA Information and Communication Accessibility Standard does not effectively address accessibility based on technological developments in the past decade.
What has TVO done to ensure that these online courses are all fully accessible to students, parents and teachers with disabilities? Could you please let us know which of these courses and other online learning resources have captioning for parents, teachers or students with hearing loss, and which have audio description of their visual content for parents, teachers or students with vision loss. For parents, teachers and students with vision loss, reading a program’s transcript (even with description of visual features) is not the same as or as good as watching a program with audio description.
During the COVID-19 crisis, teachers, students and parents are now struggling to find online teaching resources that are accessible to students with disabilities. Can you let us know where on your website a parent, teacher or student can go to quickly ascertain which TVO website content (such as these online courses) is available with captioning and/or audio description, and/or with other accessibility features? For example, we cannot find a link enabling a teacher, parent or student easily search to ascertain which of the TVO online courses have full accessibility, and which, for example, include full captioning and audio description.
Does TVO make available over-the-phone or online help from someone with knowledge about accessibility, for teachers, parents or students with disabilities who need help ensuring that they can use the educational content that TVO offers online? If so, how do they obtain this help? Finally, can you let us know who has lead responsibility and authority for ensuring the full accessibility of TVO educational and programming content, and what process is in place ensure its accessibility. Given the urgency of the situation facing students, parents and teachers with disabilities, we would very much appreciate an answer to our inquiry as soon as possible.
David Lepofsky CM, O. Ont
Chair Accessibility for Ontarians with Disabilities Act Alliance
May 5, 2020 Letter to AODA Alliance Chair David Lepofsky from Rashmi Swarup, TVO Vice President Digital Learning
Your note was forwarded to me by our customer service department. Thank you for reaching out, and my apologies for the delay in responding.
I appreciate you contacting us with your questions and to share your thoughts, particularly as we continue to evolve our digital learning resources and content to make them even more accessible for Ontarians.
TVO prides itself in being able to meet a wide variety of the educational needs Ontarians have, and we take care to ensure our approach and policy reflects this objective. We are continuously working to improve the accessibility of our content and resources.
Our videos on tvo.org, tvokids.com and in most of our ILC courses have closed captioning and described video or a DV text alternative (although in some cases where the program is an acquisition there may be a delay in posting the closed captioning and descriptive video while these elements are being created).
While YouTube does not support descriptive video audio or text, we do ensure that captions are present on all of our YouTube channels.
Our TVO ILC courses, including courses accessed through ILC Open House, have been created to meet the accessibility needs of students according to the AODA, and we ensure the course content supports both PC and Mac operating systems as well as a variety of screen readers.
Many of our newer courses offer the ability to choose from a variety of content formats (e.g video and/or article options for study) and assignment options to better cater to individual student needs. As we continue to evolve and update our courses, we are increasingly offering students the ability to choose from a variety of formats. We also ensure that there are transcripts for all of the audio in our TVO ILC courses.
We are proud to offer students completing courses through TVO ILC access to subject-specific academic support through academic advisors and to guidance counsellors who can support individual needs, all of whom are Ontario Certified Teachers.
While I appreciate that our efforts to make our content accessible to as many Ontarians as we can may not meet the level you would propose, please know that we continue to strive for improved accessibility of our digital learning resources for Ontarians.
Thank you again for your letter and feedback. If you have any additional questions, do not hesitate to reach out to me directly.
Vice President Digital Learning
Help make the world a better place through the power of learning.
May 7, 2020 Email from the AODA Alliance to the Vice President of TVO
ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
May 7, 2020
To: Rashmi Swarup
Vice President Digital Learning
Via email: email@example.com
Thank you for your May 5, 2020 email that responds to our April 27, 2020 email and for your invitation to reach out to you if we have any further questions. We do. Our April 27, 2020 email inquired into the accessibility of TVO online learning content to students, teachers and parents with disabilities who need adaptive technology to use a computer.
We have serious concerns about accessibility problems with TVO’s educational online content for students, teachers and parents and about your May 5, 2020 answers to our inquiries. We seek your leadership as TVO’s digital content vice president to get these problems promptly solved.
We ask what TVO will do now to quickly address serious accessibility problems with its online content, given your web content’s increased importance for K-12 education during the COVID-19 crisis. The Ontario Government publicly emphasized that it partnered with TVO to provide online educational content for K-12 students during the COVID-19 crisis. The Government’s “Learn at Home” website, a central hub of the Government’s offerings for parents, teachers and students, points to TVO web pages and resources, among other things.
Yet a rudimentary check of some of TVO’s educational online content quickly revealed significant and obvious accessibility problems. We don’t say that TVO has done nothing about online accessibility or has included no accessibility features at all. Where accessibility features are included, we commend this.
However, what TVO has done on the web accessibility front falls far short of what students, teachers and parents with disabilities need to effectively use TVO’s educational offerings. Among the various people with disabilities that these online barriers can hurt are people with vision loss, people with reading disabilities such as dyslexia, and people who need to use alternative technology instead of a keyboard and mouse to interact with a computer.
In the limited time we had available, just a few examples of these accessibility problems were described at the May 4, 2020 virtual Town Hall on the impact of the COVID-19-19 crisis on students with disabilities organized by the AODA Alliance and the Ontario Autism Coalition. We invite you and all TVO’s digital content staff and contributors to watch that virtual Town Hall.
Our Town Hall’s guest speaker on this topic, Ms. Karen McCall, has expertise in digital content accessibility. She explained that it took her very little time to discover these accessibility problems. If Ms. McCall could find those problems so quickly, it should have been easy for TVO or the Ministry of Education to do the same. Given the problems found in this limited review, it is our experience that one could expect an extensive audit to reveal additional problems.
Your email suggests that you believe that TVO’s educational web content complies with AODA (Accessibility for Ontarians with Disabilities Act) requirements. The deficiencies that we discovered with TVO’s educational web content call that into question. In any event, as our April 27, 2020 email to you explained, TVO and the Ontario Government must obey the typically-stronger accessibility requirements in the Ontario Human Rights Code. It cannot simply fall back on the weaker AODA accessibility standards on point, passed nine years ago, as if those were the only accessibility laws that govern here. Moreover, as an Ontario Government-owned public education network, we hope and trust that TVO knows that a Government-appointed Standards Development Committee has been reviewing those accessibility standards for some 2-3 years. Last year it circulated draft recommendations that would call for the 2011 AODA Information and Communication Accessibility Standard to be strengthened and modernized. For more background on the need to strengthen the 2011 Information and Communication Accessibility Standard, visit our accessible information and communication web page.
In light of our preliminary check of TVO’s educational web content, we are troubled by your May 5, 2020 email. It appears that you may not be fully aware of the extent of the problem. You wrote in part:
“While I appreciate that our efforts to make our content accessible to as many Ontarians as we can may not meet the level you would propose, please know that we continue to strive for improved accessibility of our digital learning resources for Ontarians.”
We are also quite concerned that you, TVO’s vice president of digital content, said in your email that it is your understanding that Youtube cannot support audio description for Youtube video content. You wrote:
“While YouTube does not support descriptive video audio or text, we do ensure that captions are present on all of our YouTube channels.”
This statement about including audio description in videos to be posted on Youtube is incorrect. It is quite possible to post content on Youtube that has been created with audio description included. Moreover, after reading your email, it took about 30 seconds and one Google search to find a link to online resources on how to add audio description to a Youtube video. We invite you to do a Google search on the terms “Youtube” and “audio description.”
In our April 27, 2020 email, we asked you if TVO makes available over-the-phone or online help from someone with knowledge about accessibility for teachers, parents or students with disabilities who need help using TVO’s online educational content. We also asked how they can get this help.” You responded:
“We are proud to offer students completing courses through TVO ILC access to subject-specific academic support through academic advisors and to guidance counsellors who can support individual needs, all of whom are Ontario Certified Teachers.”
Can you please let us know how many of these TVO advisors are trained and equipped to assist students, teachers or parents with disabilities if they encounter accessibility problems with your online content, where on your website it might indicate that such accessibility help is available, and how someone can reach a TVO person with that accessibility expertise?
As well, in our April 27, 2020 email we asked you the following:
“Can you let us know where on your website a parent, teacher or student can go to quickly ascertain which TVO website content (such as these online courses) is available with captioning and/or audio description and/or with other accessibility features?”
Your May 5, 2020 email did not answer this inquiry. We could not find this information on TVO’s website. A teacher, looking for audio-described content, would need such information to be able to readily discover what audio-described choices they have among your offerings. We would note that in contrast, Netflix enables a viewer to browse its audio-described content.
Finally, you wrote:
“We are continuously working to improve the accessibility of our content and resources.”
Our April 27, 2020 email asked who has lead responsibility and authority at TVO for ensuring the full accessibility of TVO educational and programming content and what process is in place to ensure its accessibility. Your May 5, 2020 email did not answer this question. We are eager to know who has this responsibility, what staff is allocated to this, and what plans you have in place for the accessibility improvement work that you described as “continuous.”
Given the urgency of these concerns to students, teachers and parents with disabilities who need accessible web content especially now during the COVID-19 crisis, we would welcome your prompt action and response.
David Lepofsky CM, O. Ont
Chair Accessibility for Ontarians with Disabilities Act Alliance
Premier Doug Ford
Stephen Lecce, Minister of Education,
Raymond Cho, Minister of Seniors and Accessibility
Nancy Naylor, Deputy Minister of Education
Claudine Munroe, Director of the Special Education/Success for All Branch
Denise Cole, Deputy Minister for Seniors and Accessibility
Susan Picarello, Assistant Deputy Minister, Accessibility Directorate of Ontario
Renu Mandhane, Chief Commissioner, Ontario Human Rights Commission
QP Briefing May 5, 2020
Some Ontario e-learning doesn’t work for students with disabilities
The Ford government’s at-home learning tools require some changes to be fully accessible to students with disabilities, advocates say.
Some TVO and ministry course content isn’t accessible to people with low vision, said Karen McCall, a professor who teaches about accessible media at Mohawk College and owns an accessible design firm. She was one of several experts who spoke at a virtual town hall hosted on Monday by AODA Alliance Chair David Lepofsky, a member of the province’s K-12 AODA standards committee, and Ontario Autism Coalition President Laura Kirby-McIntosh, who is also a high school teacher.
None of the stories in the “math storytime” section worked for McCall, who has low vision herself and uses a screen reader. She couldn’t find any homework in the “homework zone.”
Teachers did a good job of describing what was going on in the videos she watched, until they didn’t, she said. For instance, one math teacher didn’t read out the main formula students were to use.
“She said this formula equates to one quarter, but if I’m a student who’s trying to learn this, I have no idea what equates to one quarter,” McCall said.
Another gap came during a science class. “Everything was fine, everything was explained, until the teacher said, ‘Watch what happens,’ and then did not describe what was happening,” she said.
But the biggest problems came with the ministry of education’s own course preview site, McCall said, where her screen reader couldn’t make heads or tails of what it said.
“If they’re going to rely on this kind of content, they’ve got to make sure it’s properly accessible,” Lepofsky said of the provincial government.
Kirby-McIntosh noted that Zoom is the most accessible streaming service, but some school boards have banned teachers from using it. More top-down direction is needed to avoid these types of errors, she said.
Other experts during the town hall provided tips for educators and parents such as making sure videos were the highest quality possible, so kids with hearing loss can better lip read; and sticking to routines as much as possible, which helps many kids on the autism spectrum.
Education Minister Stephen Lecce has held two meetings with the Minister’s Advisory Council on Special Education (MACSE) during the pandemic, and is also consulting the K-12 standards development committee that Lepofsky sits on, said ministry of education spokesperson Ingrid Anderson.
Lepofsky confirmed that he’ll be speaking with Lecce on Wednesday.
“TVO has been working to make all their online content and resources accessible and compliant to AODA regulations. The Ministry will continue to work with the Agency to consider ways to enhance accessibility beyond the AODA requirements,” Anderson said in a statement. “School boards remain independently accountable for making decisions on the use of digital learning resources and collaboration tools to support students’ learning online.”
The minister’s advisory committee is “no substitute for consulting extensive grassroots disability community participation that is needed,” the AODA Alliance wrote in an April 29 letter to Lecce. A number of positions on the committee remain vacant, the group said. “Also, MACSE is designed to focus on ‘special education’ which is not addressed to students with all kinds of disabilities, due to the Government’s unduly narrow definition of special education students.”
The town hall’s last guest was Jeff Butler, the acting assistant deputy minister of student support and field services in the ministry of education. He pointed to actions the ministry has taken already, like directing school boards to consult with their special education committees and honour individual education plans; as well as working with boards to distribute assistive technology that usually lives in schools to families.
The ministry has also hosted a series of webinars for teachers to learn about special education during the pandemic. About 500 educators have attended them so far, and more are planned, he said.
Responding to McCall’s feedback about sites not working with screen readers, he said: “I absolutely am listening on that and will take that input back. It is important to us that those resources that are there are accessible for students with disabilities and students with special needs.”
He promised to continue to engage with experts, saying that their input has been “incredibly valuable.”
It’s critical for the government to carry these lessons through to when schools eventually re-open, Lepofsky said.
For instance, some students won’t be able to socially distance or wear masks due to their disabilities, if they require a close by aide or are hypersensitive to touch. “We can’t tell those kids, ‘Oh, sorry kid, you stay home, everybody else is going back to school.’”
A “surge” in education hours will be needed for some kids with disabilities, who will have fallen further behind some of their peers, Lepofsky said, giving the example of kids learning to read braille who require hand-over-hand instruction that’s impossible to conduct online.
“This is really something we can’t leave to every single school board again to try to reinvent the same wheel,” he said, calling for the provincial government to “take on leadership here.”
Kirby-McIntosh ended the stream with a message for Lecce: don’t just assemble a “spiffy webpage with a blizzard of links,” but consult with experts and provide school boards with top-down direction on best practices.
“Please learn from this town hall,” she said, and gather ideas from the front-line people teaching kids with disabilities during the pandemic.
“The premier committed at the beginning of this crisis to protecting those who are most vulnerable,” she said. “Well, surely a third of a million Ontario students with disabilities are among those most vulnerable.”