DLRP Web cast February 19, 2003 Access to Distance Education: Legal and Technical Issues Presenter: Curtis Edmonds Rachel: Hi, good afternoon everybody, and welcome to the Web cast on access to distance education: Legal and technical issues. My name is Rachel Kosoy. I am with the Disability Law Resource Project, your host for today's event. I'm the one who will be moderating or otherwise said voicing your questions to the presenter. And shortly I will be introducing our presenter who is Curtis Edmonds. First, I want to quickly address just a couple technical issues. If anybody has any technical difficulties today, please give us a call. We've got people who are standing by and can help you. The phone number to reach us is (713)-520- 0232. I also want to let you know that Curtis will be taking questions about three times during the presentation. So in order to submit a question, if you look on your Real One player, there should be a button at the bottom that you can click to submit a question. If that doesn't work for you, you can simply address an E-mail to webcast@ILRU.org. So please go ahead, you can send questions now or at any point during the presentation, and I will be getting those E-mails and voicing them to Curtis for you. Okay, today's topic is access to distance education: Legal and technical issues. Our presenter today, who we are very glad to have with us, is Curtis Edmonds. Curtis is an attorney who's Alma mater is University of Texas, whoa, in case any of you don't know, my office is based in Texas, so we are all very proud of that. Curtis has served on the staff of governor George W. Bush, governor ridge Perry and senator Phil Gramm. He has authorized ADA technical assistance materials, as well as two law review articles on the Americans with Disabilities Act. Currently, he is with the Southeast DBTAC, which is our counterpart in the southeast region, and there he is providing training and technical assistance on information technology access for educational entities. So without further ado, Curtis, we're glad to have you here and I'm going to turn it over to you. Curtis: Thank you, Rachel. I appreciate it. We're part of Georgia Tech and I'm out of Atlanta, Georgia. We are working of course on the DBTAC project. We're also working under a grant from the office of postsecondary education at the U.S. Department of Education. And we're doing a study on research on accessible distance education here at Georgia Tech, which we will expand on a nationwide basis here in the next three years. Just to give you a very brief synopsis of what I'm talking about, online distance education, that's distance education that's over the Internet that is what is called asynchronous. I can take place any time, unlike previous distance education, which relied on television shows or the audio cassettes or video cassettes. The online distance education is becoming increasingly prevalent, but many students with disabilities continue to experience barriers in accessing online education. Many of the stakeholders, educators, I. T. departments at universities are unaware of potential electronic barriers to access. Many do not know the legal responsibility to provide access for students with disabilities, and many are not familiar with the methods and resources needed to improve access to distance learning programs. The result of this is that students can disabilities are limited in the types of courses they can take, and their overall learning strategies, all of their opportunities really, are limited because they don't have access to the same types of online resources that other students have. I'll talk for just a few minutes about why this is such a big issue now. Distance education is becoming more and more prevalent in two-year institutions and four year institutions. About one-third of all the institutions of higher learning surveyed said that they offered distance education courses. And an additional 20 percent said that they would offer such courses in the future. That was in a 1995 study. In 1997, about 1.6 million students were enrolled in various distance learning courses. In fact, we don't know in 2003 how many students are enrolled because the numbers are simply growing too fast for the researchers to keep count. As of 1997, there were about 54,000 courses, triple the number that there were in 1995, and about 15,000 of those online courses were being offered for college credit. And more and more schools are switching over from their traditional distance learning to correspondence courses, the video cassettes and switching over to asynchronous online distance education. In fact, the schools in the survey that said that they would soon start distance education programs that did not already have them were looking exclusively at using the Internet to offer those courses. The most recent numbers that we have on the prevalence of online distance learning was from the state of Oregon. In 1998, Oregon had a certain number of distance education courses. In 2001, they had almost a 350 percent increase in the number of students and an almost 550 percent increase in the number of courses. So you can see that's really becoming the way to deliver higher education is through these asynchronous, online courses. And in fact, students with disabilities are participating in these courses. They're not being completely shut out yet, and a study from the Department of Education found that 27.6 percent of students with disabilities were more satisfied with their distance learning than their regular learning. And that's kind of a low number, but it's above the number of students without disabilities who were satisfied, only 22 percent of students were not satisfied by their experience. However, the fact that this is available does not mean that it's accessible. The design of many distance-learning courses offered by these institutions of higher learning erects barriers to the full participation of students with disabilities and also to instructors who have disabilities. The main concern is that the information technology that's being offered by these institutions is not compatible with the devices that people with disabilities use. There are thousands of different assistive technology devices. We have a database here at Georgia Tech under a program called assistive tech.net and that's available on line where there are literally thousands of different devices that people use in their every day lives. A lot of them allow people to access to Internet and computers; but many people don't realize that the fact that these assistive technology devices are available does not always mean that people with disabilities will have access to your information technology. If you are designing a distance education course and you're not providing access to these students who use this assistive technology, those students will not be able to take advantage of your course. This can result in students with disabilities not being able to participate in academics or in career preparation. I'm just going to give you a very quick run down of the different types of assistive technology devices that are out there and the barriers that can result when people who use these devices try to access online learning. And if you're familiar with web accessibility at all, a lot of the same issues come into play, although I'll talk a little bit about later second generation problems that are unique to distance learning. First, the group that most people are aware of is students who have visual impairments, students who are blind or students who have low vision. Students who are blind use a various types of screen readers. The product names include JAWS, WindowEyes or Home Page Reader. These programs speak the text on a web page or an online document so that someone can hear. If you have someone who is deaf/blind, a vision impairment and a hearing impairment, typically these individuals will use assistive technology such as refreshable Braille that provides a stream of characters in Braille that a person can feel and that they can then go and access the information that way. The problem is if you have graphic al information, whether that's on an HTML page, whether that's in an Adobe PDF document, whether that's a Microsoft PowerPoint slide, all of these are displayed in online education as graphics, and the screen readers and the refreshable Braille simply can't access those graphics unless someone makes the effort to provide Alt tags or provide descriptions or what have you to make sure the information is as readily available to people with disabilities as it is to everyone else. Additionally, you have people taking advantage of screen magnifiers or other types of assistive technology for people who have low vision. This can include modifying one's browser so that you can use what's called a cascading style sheet to -- so that all of the text on a given web page or in a given document is presented in large enough print for that person to read. However, if pages are not well designed, if they used a lot of different tables and charts, these can be problematic for those students as well. The solution to that is to make sure that the Internet sites are designed using relative values so that the tables and the charts can stretch to accommodate someone who is using larger text or a magnifier. Additionally, you have students with learning disabilities and we really don't know a lot about the barriers that they're experiencing. We're currently conducting here at Georgia Tech a research project with a number of Georgia students to determine exactly what the needs of those students are. One thing that we found so far, not that we've found through this project, but has been found through the other research, is that if the information is cluttered or if the screen layout changes constantly, this can be confusing for some students who have learning disabilities. Students who have mobility impairments or manual dexterity limitations can use various different kinds of assistive technologies instead of a keyboard. These students may use trackballs or other devices to input information. In an online quiz format, both Blackboard and WebCT, the two main providers used time quizzes and people are required to write in essays or what have you in a certain length of time that's the same for every student. And someone who has a learning disability or a manual dexterity problem and can't enter in the information that fast or process that information can't get an accommodation of extra time on those programs. And additionally, a lot -- this is very common -- on the Blackboard and WebCT version that is I've been using is that there is no way to skip repetitive links. Both Blackboard and WebCT use menus on the left-hand side that's familiar to anyone who has used that kind of website and there is no way to skip over all of the links and go directly to the main content of a page. There are some other issues that are in the 508 standards, for example, if you have students that have certain kinds of seizure disorders that are photosensitive using flashing graphics or other displays can cause those individuals to experience seizures. One of the most common problems in accessibility for online education is that you have students who have hearing impairments but there is some sort of online video presentation that's going on. In this Web cast, if you're on via the web, you'll notice that my words are being captioned and I hope that I'm not talking too fast for the people who are reading the captions. But you can see that someone who has a hearing impairment could access this Web cast. If, instead, I was in a studio and talking to you over a camera, which is good for you and me both, because you don't necessarily want to see what I look like, and there wasn't any captioning provided, all a person with a hearing impairment could see would just be my talking head and they wouldn't be able to get the information that I'm providing to you today. And there are ways to provide captioning for these online video lectures that are used very commonly in distance learning. Well, these are the barriers, but there are also benefits to having your online education structured in such a way so that it's accessible. It results in courses that are easier to use and understand for everybody. For example, if you have an accessible course, an accessible PowerPoint presentation and we'll talk briefly about how to make those, you actually are able to search within the PowerPoint presentation, which could be hundreds of slides for the one piece of information that you need. It wouldn't be there if the PowerPoint presentation wasn't accessible. If you have somebody who is doing an online lecture and doesn't have very good communication skills, you could have a professor who is from another country and has a thick accent, you could have somebody like me that has a very bad Texas accent, providing captioning helps you understand what that individual is actually saying. Additionally, more and more students are accessing the web through a variety of different devices, not just simple desk top or laptop computers. Accessible web pages in distance education can be more easily accessed by telephones, the different cell phones that you have that have the different displays, wireless devices, hand-held computers, palm pilots, any of these -- it's much more helpful to have an accessible page that you're using rather than to just have an inaccessible page that can't be accessed by these different devices. You also have situations where you have students that don't have good English literacy skills, people from different countries, people who use different languages. These people can be helped by having additional text uel information. Additionally, if you have an instructor with a disability, these instructors can benefit from having online education. They can be better able to participate in online education is the courseware is fully accessible to meet their needs. The next up is the legal requirements and I'll stop and take questions before I start talking about all the wonderful complicated legal stuff. >> Rachel: Okay, great. We have a number of questions that have come in. A bunch of them, Curtis, because I know where you're headed I'm going to hold until later in the presentation, but I'll throw a couple at you. Somebody wrote in and they were interested in videos, and so I know you've addressed it some, but maybe you can repeat and add a little bit. They basically said that a lot of the videos are primarily lecture, but increasingly they're also using graphics, PowerPoint, et cetera, and they wanted to know about video accessibility for people with visual impairments. And then they also wanted to know can they caption an existing video. >> Curtis: I'll answer the last question first because it's a little bit easier. You can caption an existing video. The software that you would use for that is called MAGpie. It was developed by the national center for accessible media up in Boston. The way that it works is you take a file off of the Internet. You save it within the MAGpie. MAGpie is basically a database program. It allows you to identify the speaker, it allows you to type in the words that the speaker is using, and it also allows you to type in a time code. Basically what you have is you have the video running up in a corner. You're able to pause it every so often, type in the words, put in the time code for the video, and what the result of that is that you have a captioned presentation, and then you save it in one of several different formats that can be used by different players such as real audio or Windows Media Player. That individual can then turn on the captioning that's within those Media Players, and then be able to see the captioned video. And if you go to the national center for accessible media website, that's NCAM.org, they have some samples available. And it's a lot easier, really, to caption an online video than it is to caption something that's on videotape. That can be very expensive and time consume assuming because it's different technology. Once you get MAGpie to caption your video, you can actually save it and you'll have something captioned on those mediums that as cheaper and easier to use. In terms of individuals who have visual impairments, the newest generations of the courseware allows an integration between the talking head and the PowerPoint presentation that they may be running or different graphics such as different Flash animations, and individuals need to take professors or lectures or whoever -- need to take the names of students who have visual disabilities into account when they're putting together these courses. It could be that you provide audio description within the video. It could be if you're running a PowerPoint that you simply say the information that's on the PowerPoint while you're doing the different lecture. Unfortunately, this is one of those areas where the section 508 standards, the very basic minimum standards that we have don't address it very well. So what we have to do and what we're working on is putting together different standards and guidelines and tips so that people can use these videos, but not leave students with various disabilities out of the loop. >> Rachel: Okay, and just for anybody who doesn't know, can you describe for people what audio description is. >> Curtis: Audio description is away of describing the elements within a video shot, in other words, if I was audio describing now, I would say that I was sitting in a chair, talking on a telephone, in a small conference room. I have my watch off and it's in my right hand so I can determine how much time I'm taking and not have -- not take everybody's time. I would be explaining all of the things that you can't see. It is a lot more difficult than it sounds, especially when you're doing a movie where you're having to explain just all of the different action that's going on on the screen, and you're trying to do it within the different gaps, especially in a movie in dialogue. And you can actually on some television programs now, you can turn on your secondary channel, your SAP channel and you can hear an audio description of some of the TV shows and the TV movies that are coming on. So you get a good idea of what's involved in trying to audio describe visual information to someone who has a visual impairment. >> Rachel: Okay, great. I think that was helpful for people. I'm getting feedback from our captioner that you're doing very well, but if you wanted to slow down just a little bit, she wouldn't mind. >> Curtis: Okay. >> Rachel: One other question to throw at you at this point, and then you can move on. Are you going to address accessible textbooks and who is responsible for providing accessible textbooks? >> Curtis: Not at this time, no. Obviously that's an issue, and obviously there are just a huge number of legal problems that are involved in making textbooks accessible. Obviously the publishers, especially in this ERA where you have all of the file sharing that's going on want to make sure they have control over their work and I know that here in Georgia they're working on a new law about accessible textbooks and whose responsibility it is. And that's kind of outside of what I'm talking about today, but I recognize that it's a serious issue. >> Rachel: Okay, great. Okay, the rest of the questions I'm going to hold for later. >> Curtis: Okay, let's talk a little bit about the law. There is not anyone law that applies to all of this, unfortunately. You have really a lot of different laws that were written before the explosion in accessible online education that really don't address the topic, but provide kind of a philosophical framework where we can talk about what the responsibilities that a given institution has in terms of accessible education. First of all, you have the ADA, which was passed in 1990, four years before the Internet was really available to the general population at large. Title II of the ADA and Title III of the ADA both have applications to distance education. Title II has a very general requirement for entities to make reasonable modifications in policies, practices and procedures when the modifications are necessary to avoid discrimination. Unless the public entity can demonstrate that making the modifications would fundamentally alter the nature of the services, programs or activities. Title III has a similar requirement and additionally, both Title II and Title III allow an entity to get out of compliance when doing so would be an undue burden. Title II applies to the public college systems, Title III applies to places of public accommodation, and that includes private colleges and universities. Additionally, both titles have a requirement that communication with people with disabilities be as effective as communication with others. And this communication can and I think does apply to education because really that's what education is. It's communication. Now, as I said, the ADA was passed in 1990, and in fact about the time that it was passed, it was actually illegal for private people to be on the Internet because it was run by the Department of Defense. So nobody at the time even thought that you would have online distance education. It just wasn't something that Congress or the ad add community or the administration were thinking about when they wrote the law. It's even when they wrote the regulations, you simply don't have a great deal of law on this subject. The primary piece that people look at when they look at the ADA and all of the online information is a letter opinion that was written by a fellow named Duvall Patrick in response to an inquiry from senator Harkin. That letter which is available on the Department of Justice website says the covered entities under the ADA must provide effective communication regardless of whether they generally communicate through print media, audio media or computerized media such as the Internet. Covered entities that use the Internet for communications regarding programs, goods or services, must be prepared to offer those communications through accessible means as well. But the department has not and does not have any guidance or technical assistance or standards under the ADA that individuals can use to make accessible online education available. There is not any ruling that says what is accessible and what is not accessible in terms of the ADA. However, this does not stop people from going to court. There are actually two different cases under the ADA regarding accessibility of electronic materials. And it's really kind of funny, is that both of them came within about a two-week period in 2002 after we had waited really 12 years for there to be any kind of legal action. You get two cases from two different courts in about the same month, and of course the different courts found differently. So we have two different opinions that sort of contradict each other. The first one happened here in Atlanta. There was a lawsuit against the Metropolitan Atlanta Rapid Transportation Authority involving a lot of different people with different kinds of disabilities who were claiming multiple ADA violations against MARTA. One of the things they were complaining about, in addition to the normal things that you get regarding service and paratransit delays, and inaccessible stations and what have you, one of the problems was that the MARTA website was not accessible, and in fact, MARTA employees even testified that their website was not accessible. The route information that you get, if you go -- and if you want to check it out, you can. I think the website address is --. The route information is done through maps in Adobe PDF format. PDF has a number of accessibility problems. It can handle straight text very well, but it doesn't handle maps very well, and they're very difficult -- I've experienced -- even to read if you are sighted. It's hard to interpret. The court in that case looked at the situation and said there is a very specific Title II requirement that transportation entities provide schedule information in an accessible format and because the only way you can get the schedule information is either from a little brochure that they hand out or online, that MARTA violated ADA because they did not have this in an accessible format. And the court looked at the MARTA website and said this isn't accessible, and we are issuing an injunction against you. We want you to work on it and then get back to us within so many days and we'll see what you've done to make sure that every one has equivalent access to this. The court didn't set any standards or requirements, just said go do it. Then about two or three weeks later you had another lawsuit against Southwest Airlines involving a person who was blind who was trying to make an online purchase of some tickets on the southwest website. They weren't able to do that. The court in that case found that the Southwest Airlines website was not a place of public accommodation. This was a court in Florida. The case is access now vs. gumson, and the court found that the proper place of public accommodation was an airport or a ticket office in the physical world that sold southwest tickets. Because these places existed in the physical world and not in the online world -- as well in the online world I should say, that person could go to the ticket office and buy those tickets and therefore that the website was not a place of public accommodation. The question on this end, my question is the Eleventh circuit here in Atlanta which covers Florida has already said that the definition of a place of public accommodation is flexible. There was a case where they overruled a Florida court in the case of RENDON versus valley crest where the place of public accommodation was a telephone number where contestants could call to get on a game so. The Eleventh circuit said that's a place of public accommodation. The Florida court who looked at the Southwest Airlines case determined that that decision didn't apply because it wasn't about the Internet. So we're waiting on the Eleventh circuit to decide if they're going to hear this case, see if it goes up on appeal, and see if this determination is actually correct. But the Southwest Airlines court didn't even address the question of whether it was accessible. And in fact, since the lawsuit, Southwest has gone and made some improvements in its web page. It's not completely accessible yet. I wouldn't want to say that, but they have -- they have begun efforts to make it more usable for people. So that's the ADA. And then you have section 508, which is part of the Rehabilitation Act. It requires that federal departments or agencies must ensure absent an undue burden that the electronics information technology they acquire is accessible to individuals with disabilities. What the federal government did -- what section 508 did, was they got the Access Board which is a small federal agency that drafted a lot of the ADA architectural regulations and said we want you to come up with a set of standards. And which is what they did. They came up with the Section 508 web access standards. You can go to section 508.gov on the Internet and look at those standards in terms of Internet accessibility, there are only about 14 different standards that you're looking at. And they said these are going to be the standards, but those standards have a limited application. They're only applying under the terms of Section 508 to programs and services of the federal government. Now in 1999, the Department of Education said that they interpreted section 508 to have a wider meaning. They interpreted it to apply to state entities including some public colleges and universities. And you can look for that letter and find it online at the RESNA website. I don't have an actual site to that, but a federal court has not adopted that administrative interpretation. And additionally, the Office of Civil Rights of the Department of Education has said that they're not going to enforce Section 508 against the different educational institutions; but that you have an interpretation that says that it's required. Many universities, the University of Wisconsin at Madison was one example, have adopted Section 508 voluntarily as part of their accessibility standards, and the way they did it at the University of Wisconsin Madison is that they applied it to newly designed pages and they're also going back to pages published before the policy went into effect and they're trying to receipt row fit those pages as well. While the ADA doesn't have any standards, universities and colleges that voluntarily adopt the Section 508 standards or a different standards will more than likely be able to show, in case of litigation, that they are complying with the ADA by following a universally accepted set of standards and trying to make sure that they're providing access to students by using those standards. Additionally, there are state laws that require accessibility for a number of different audiences. I know in Texas there is a law that requires state agency websites to be accessible. In my region, Kentucky and North Carolina have both recently passed laws that require all state entities, including public education, different colleges and universities in those states to provide accessibility to information technology. And as more and more states begin to look at this issue, you can expect a number of different laws. If you go to the RESNA website they have a listing of some of the different states that have adopted laws or regulations on Section 508. So I'll stop here and see if there are any more questions. >> Rachel: Yes, we have questions. Okay, a couple are about these legal -- the policy directive as well as the lawsuits that you mentioned. >> Curtis: Right. >> Rachel: One is what are the two lawsuits actually mean for online distance education? What should people take away from this? >> Curtis: Well, it's very difficult to argue that the MARTA website is going to have any real application other than to transportation entities, because it's very -- it's looking at a very specific part of the ADA Title II regulations that only apply to transportation. The next question is if you have a course that is only offered online, and there are some courses that are only offered online. Some are going to be offered on a campus setting and some aren't and you can have a situation where a course is available on campus one semester and via distance learning the other. If the only way that you can get to a given course is to get it online, the question is, is that a place of public accommodation? With the Southwest lawsuit, the decision kind of turned on the fact that you could get Southwest tickets through a travel agents, at an airport, over the telephone, in a number of various different ways, but if the only way you can access an online course is to go through the Internet, that may make it a place of public accommodation. So it could be that the rational used by the court in the Southwest Airlines case is not going to apply to online education. And additionally, different courts could decide this different ways, and since we haven't had any litigation on this, it's kind of reckless for me to speculate exactly how a court might react if we're talking about distance education. So I don't know if that really answers it, but it's kind of a situation where we're going to have to wait and see what the courts do when they get these cases. >> Rachel: Okay, are you an attorney? >> Curtis: Yes, I am. >> Rachel: I can tell. Okay, well, let me give this one a shot. Can you talk a little more about the DOJ policy directive that you mentioned and what is its legal application for making distance learning programs accessible? And the last comment is how would you recommend it be used to encourage educational entities to pay attention to access issues? >> Curtis: Well, think obviously people should be aware of it. That would be the first thing, and it is available on the Department of Justice website. I don't have the link to it right now. I can tell you that it was issued by senator Tom Harkin if that makes it a little bit easier to find using their search engine. As to what value it has, we really don't know. There is only been one attempt so far by the Department of Justice to do more than just have a policy letter. In 1999, they filed a friend of the court brief with the Fifth Circuit in New Orleans on a case involving a person who has a psychiatric disability. The case is called hooks vs. O. K. bridge. The O. K. bridge website was a website where people could go and play bridge, play cards. This individual was asked to leave the website because he had -- there were some allegations he cheated, there were some allegations that he had been rude or uncivil in the different online forums and he sued. The Department of Justice filed a brief that said that the ADA applied to the O. K. bridge website. The Fifth Circuit ruled in the case, but they didn't address the issues that were in the department's brief. Instead, they found that the -- even if the ADA did apply, that the O. K. bridge people did not have any actual knowledge that the plaintiff actually had a disability, that he had these psychiatric problems, and therefore, they could not have discriminated against him. So other than that letter and that brief, there hasn't been a whole lot from the Department of Justice, at least not that I've seen, that would lead you to suspect that they were going to do anything else with online learning. In terms of enforcement, there has been one enforcement that was done by the Office of Civil Rights against a number of colleges in California, and in fact, the real leader in accessible online education so far is the California Community college system because they have had a complaint filed against them. But in terms of what you can do with that letter, I think you can make it known to people. The problem is that it's still open to interpretation. It doesn't come out and say distance education is covered. It doesn't come out and say you have to provide Alt tags for every image. So it's kind of -- there are kind of limits on what you can do to provide information to decision-makers to make sure that they're willing to do the right thing and make distance education accessible. >> Rachel: Okay. Switching gears a little bit, people want to know what standards you recommend for schools to use when they're working on the accessibility of their websites? >> Curtis: I would really recommend the W3C standards and those are the standards that were adopted by the web accessibility initiative, the WAI, and they're available on the W3C website, that's W3C.org. W3C stands for the World Wide Web Consortium, so you have the three W.'s and a C. and so that's the name that they decided to do. If you're talking to the techIES, the people that are really going and coding these sites, the W3C standards, following those is really your best guarantee to ensure that everything is going to be accessible. If you go to any of the Southeast DBTAC website, any of our web courses, you'll see at the very bottom that we have triple A. certification from W3C, meaning that we have passed all of the different standards. You can still have a web page that is accessible and usable by following just the Section 508 standards, but they're not quite as detailed. On the other hand, there they're a lot easier to follow and a lot easier for people to understand. So it kind of depends on the level of sophistication of the people that you're actually dealing with. If you're dealing with people who have a really good technical knowledge of HTML and the different coding issues, I would really want to push them toward the W3C. If you're working really more with K. through 12 or nonprofits who people who don't really have that in-depth knowledge, I would really push them towards the 508 standards because they're a little bit easier to understand and there is a lot more technical assistance that's driven by 508 than the W3C. I hope that's made everything clear because I'm not quite sure I understand what I said. >> Rachel: All right, I think I got it. Do you want to clarify anything? >> Curtis: The next thing I want to clarify is that the standards by themselves -- there is so much more involved in distance education. It's so much more complicated, is that you can have everybody follow the 508 standards. Everybody follow the W3C standards and it can still be inaccessible because the standards only address H. T. H. L. They don't address the different types of information that you get in a distance Ed course. There are so many more different programs and services that you can plug in using the different courseware. And these can cause problems, what I call second generation problems. I'll talk about that next. >> Rachel: You do have a question here but you can let me know if you want to put off answering it about which distance learning programs or courseware you think actually provides best accessibility. >> Curtis: I can answer that to a very limited degree. I have looked at courses recently under both Blackboard and WebCT and I haven't looked at any of the other E. colleges, one that's called top class, one that's called Jones. There are different kinds of courseware. I've looked at Black board in a project we're working on with the University of Louisville to get grant funding to make all of their offerings accessible. At Georgia Tech they use WebCT and we did have funding to try to make the WebCT more accessible. Both have done, from what I understand, a pretty good job in making sure that the courseware is more accessible than it was. Both black board and WebCT have people on staff that have experience in accessibility. The newest versions of both programs are supposed to be fully 508 compliant. The versions that are used now that I have actually seen in action have a few problems. Most notably, there is no way to skip navigation, both of them have those left-hand side menus. You have to read every single one of the items on those menus before you can get to the main navigation. Both programs use frames. The frames are not always labeled. You have to switch back and forth between the different frames in order to make sure that you get to the content that you need. There are ways to do that, but frames are really not very good if you're trying to reach total accessibility. There is different ways for you to do that that don't actually involve the use of frames. The problem is, of course, everything that I say is really obsolete because the newest versions, when they come out are going to address a lot of these issues and since I haven't seen them, I can't tell you which one is better than the other one. I can tell you that it's better than it was. It's better than it's been in a long time, but the real problem is not the courseware so much, is that it's the individual faculty members and how they use the courseware and how they use it to create inaccessible items within their distance education. >> Rachel: Well, that brings up another question that is here, which is this person is saying, my goodness, we're going to have to train almost everybody, you know, who works here. And how can we go about doing that and do you know of resources for helping us do that? >> Curtis: Yes, I do, but it's not ready yet. My center, the Center for Assistive Technology and Environmental Access here at Georgia Tech is funded in a grant that I wrote to put together a course, a ten module course. It's actually funded by the DBTAC and by the Office of Postsecondary Education to put together a ten module course for faculty members on how to make distance education accessible. It covers all of the different types of programs that people use to put content into these courses. That can be Word, it can be Excel, it could be PDF, it could be Flash and what I'm going to be talking about here in a minute is PowerPoint. That is going to be available sometime this summer and we're going to roll out the different modules as they're completed. The website that we're going to be using is access E. learning.net. Don't go there now. It's not up and running yet. Hopefully we'll have some stuff up there by this summer that will be a free tutorial, free for the first three years of the project, that faculty members can use to go in and take to get different information. As we have the tutorials completed, we'll also have technical assistance material completed that will just be very brief guidelines. We might have some checklists, I don't know what all we're going to have because we haven't written it yet, but just different guidance that faculty can take and use to create -- excuse me -- create accessibility on these courses. >> Rachel: Okay, great. Why don't you continue on and these other questions I can ask at the end. >> Curtis: Okay. The first thing is that accessibility is not very widespread. There have been two studies from different universities, one at the University of Wisconsin and one at the University of Washington that have looked at how accessible these programs are. And it's very difficult to evaluate the accessibility of the different programs, simply because you have to pay to access the courses. Okay? So what they did is they just looked at the web pages. The pages that you would go to if you were interested in enrolling in a distance education course. In only 24 percent of those pages that they looked at -- they looked at 124 different programs and only 24 percent of those passed the Bobby evaluation. And the numbers were consistent. The second study looked at 3300 different pages and found that only about 23 percent of those pages were accessible. So even before you get to the course you've got to navigate the website to get to the course and that's not accessible so we know there are problems. You have the different types of courseware, I've talked about that very briefly. This courseware is great for faculty members because you have faculty members who don't know HTML, who don't know how to create stuff on the Internet, but they can take this courseware and with only a very little bit of training, they can put together a pretty good online course. Whether it's accessible or not is another question, but they can take it and put it together and have an online course that most students are going to be able to access without having to know too much about accessibility. However, what happens is that they can plug in all sorts of different information into this courseware that's not necessarily going to be accessible. And just having the courseware, even if you have the courseware 100 percent accessible, which the new versions promise to be, you still have all this other inaccessible content that people can't use. So this is a real challenge for a faculty person. If they're creating these different documents, they have to know how to create them in an accessible way. And the terminology that I use here is second generation accessibility. The first generation of accessibility is the Section 508 standards, the HTML accessibility. It is making sure that the shell of the program is accessible. The courseware people are working on that and see how well they eventually do. The second generation is the content part of the course. And that can be a Word document, it can be an Excel spreadsheet. It could be any number of things that a person can fit into a course. The one course in Georgia where one of our partners has worked the make accessible was a course on Soviet film and the course involved just hours an hours an hours of watching all these different movies and all of them had to be captioned otherwise they wouldn't have been accessible and there is no way that a courseware product can look at any kind of content to determine whether it's accessible or not. The faculty person -- the instructor has to take responsibility. And it's a lot harder because there aren't the section 508 standards that apply to Word documents or Excel spreadsheets or what have you. And the people who are responsible for this faculty member simply don't have, in many cases, not universally, but a lot of them don't have the technical background they need to create accessible documents. >> Rachel: You know what, Curtis, I'm sorry to jump in, but a question came in that's exactly on point. This comes from somebody who works -- who serves deaf and hard of hearing students in the postsecondary environment, and she's basically asking to evaluate asynchronous webs. Are there any good evaluation tools available because she says a lot of the courses they're working on incorporate block board and other tools. So it's not just -- she can't just use W3C or Bobby. >> Curtis: Right. You can't use Bobby. You have to look at all of the different elements of the course to determine whether they're accessible. There are some shortcuts you can do. For videos, for example, all you have to do turn on the captioning and determine whether they're captioned. That's really easy to evaluate. Flash animations are hard. You have to test them with a screen reader. Flash is supposed to be more accessible than it is, but it's hard to read animations that are accessible. Word document, you have to look at each page and see whether there are things in those documents that aren't accessible, whether those are charts, art graphics or what have you. There is not a tool like Bobby that you can just turn on and check every page at once. You've got to do it on a case-by-case basis and what we're hopefully going to get out of our project within the next few years, and we don't know how long that's going to be, is techniques, tricks, maybe even software, maybe even tools that people can use and can try to make these things accessible, but in terms of an evaluation for second generation stuff it's just not there yet. >> Rachel: So is there even -- looks like she wants to know is there some sort of checklist she can go through which maybe might not tell her how to correct the mistakes or the parts that are not accessible, but so that at least she knows if she's looking at all the areas she needs to look at? >> Curtis: That's one thing we're going to try to develop in this -- under this grant and we don't have it yet. But I don't know of anybody else that has it either. So that's not a good answer. We're simply just very early on in this process of providing people all the information they need to make sure it's accessible. Just really briefly, to run you through PowerPoint because it's one of the ones that is used most often and it's very common and there are some very specific accessibility problems. You can run PowerPoint through a java plug in in Internet explorer and it will display each PowerPoint slide as a graphic, but you will not get the text of that graphic. Someone who is going in there and is blind and using a screen reader will not be able to access any of the information. You can use a different kind of plug in to present the PowerPoint to transfer into HTML. That uses frames. You can view the text. It is very difficult to navigate and you can't search. What we are proposing in our project is that people take this approach: Save all of the PowerPoint slides as graphic files and there is an easy way to do that within PowerPoint. Put those in a folder. Create an HTML page that incorporates all of the text of each of the PowerPoints, intercepts the images and put Alt text with the images that gives the numbers of the slides, don't try to describe them because you'll have text right underneath each one of those images that has the text of the PowerPoint. And you can make the text of that PowerPoint very small. You can match the text to the background so that people who are sighted won't even be able to see it, but a screen reader can still pick it up. And you use very simple HTML code and what you have is an HTML page that has all the images from the slides. It is very easy to navigate up and down within that HTML page and is completely accessible. The only images on that page will be the images in the PowerPoint slides. Those will be appropriately Alt tagged and all of the text will -- of the PowerPoint will be presented within HTML. Now, there are still some things you have to do if you have images in the PowerPoint. If you use graphs or charts or videos, you'd have to address each one of those separately, but this is a very simple way once you get used to actually doing it to put a PowerPoint presentation in an HTML file in an accessible format. And we can actually put together a template in one of the Word processing documents that lets you do this fairly quickly. So it's not something that's really all that hard to do. You just have to kind of get in the habit of doing it. Two good things about this approach: First of all, the HTML page loads a lot faster than a PowerPoint presentation would. And people who use 28.8 modems or use wireless devices, it's a lot easier for them to access it that way than it is to download a whole PowerPoint with all the different stuff that you get in a PowerPoint presentation. Also, the text is searchable. You can search it while you're reading the presentation. You can search for key words, and additionally, if you have it in a public place, search engines can pick it up, too, because search engines look at the text of a document. So that's just one thing that we're putting together that's going to be the first module that we have on the access E. learning.net website. And it's just a simple trick that anybody can use to make sure that the PowerPoint part of a distance Ed course is accessible. So that's about all I have. We have on few more minutes for questions I hope. >> Rachel: Yes, we do. We have up to almost a half hour more that we don't need to use it, but we won't get you off until then. >> Curtis: Okay, good. >> Rachel: I do have a couple additional questions. The first one is since black board and other systems set their format themselves, you know, like no skip links, et cetera, what can we do when working within one of those frameworks to make online courses more accessible? >> Curtis: I've actually asked that question to some people who are kind of the experts and I never really got a satisfactory answer. I was really hoping that there was away within black board to kind of manipulate kind of the HTML code to kind of put in some of these skips. Just to give you a very basic idea of what we're talking about, you put in a little piece of HTML code and the classic way you do it is to have a graphic that is zero pixels high and zero pixels wide. A pixel is the tiniest little dot on your computer screen. Zero means that for all practical purposes it's not there. You attach that imaginary image to a link that allows you to skip within the page. A good example of pages that don't have this is the New York types website. If you go there, you'll notice on the left-hand side there is a very, very long list of all the different sections in the newspaper. If you go there, you can hit the tab key and the tab key will allow you to go through and tab between all the different links and one thing that's fun to do in a training is go to that page and tab through and see how many times you have to hit the tab key before you get to a story. You pick the story you want to read and then you see how many times you have to hit the tab key to get to the content of the story. Because there isn't any way to skip all that navigation, a screen reader has to read every one of those links on the left side of that page, and it's very boring and very repetitive and it's not accessible because it takes ten times as long to get the information that anybody else can just go to that site and pick up. And black board doesn't have that. WebCT, as far as I can determine, doesn't have that and it's a very small piece of code. It takes about two minutes to write one of these things and you've got to make sure you put it in the right place. So I'm hopeful that the new versions will have this. I know that the information has been given back to black board, but unfortunately I don't know of away that you can go in and change the courseware to -- given the systems that we have now to make that accessible. >> Rachel: Okay. It's helpful to know exactly what the lay of the land is even if we're not able to do exactly what we want to do at this point. So the information you're giving is very helpful. Okay, next question: You mentioned that the Access Board adopted the W3C standards. It's my understanding that these standards were not adopted by the Access Board. Most people thought they would be, but to everyone's surprise, they did not adopt them in their entirety. Can you clarify, please? >> Curtis: I don't believe I said that, and if I said it, I misspoke or mistaken. They adopted the section 508 standards. They did not adopt the W3C standards. What I was saying is that institutions should consider as part of their own policy adopting the W3C stands afrmentds no, the Access Board didn't have anything to do with those standards. Those were industry developed. The Access Board chose not to adopt them and instead chose to adopt a different set of standards. If you go to the section 508.gov website, there is kind of a table that shows where the different parts of the Section 508 intersect with the W3C standards. So, no, obviously the Access Board didn't adopt that. >> Rachel: Okay, thanks for clarity. This question takes us back to training materials. >> Curtis: Oh, good. >> Rachel: And they'd like to know will you offer some training materials for faculty who are not willing to go on line and teach themselves? >> Curtis: Well, we're still developing this, and since we have the extra half hour, I'll go ahead and describe the project that we are working on since I wrote the grant, I can do that. We got some money from the Office of Postsecondary Education to go in and basically do three things. First of all, is the development of the accessible online course. What we said we would do is put together the course. The course would have ten modules. There would be an introductory module. We would have a module that focused on PowerPoint, on Excel, on Flash, on HTML, I think there are two modules on HTML, on Word, on PDF, all of the different element that is are generally found in courseware. This is all going to be online. However, we also said that we would put together technical assistance material. We haven't started on that yet, simply because we are trying to get different people at Georgia Tech to evaluate the course, different faculty members to actually take the course, have them tell us what's helpful and what's not helpful. And we'll take their recommendations into account as we develop the technical assistance material. We're going to try to make it as timely as possible. If a faculty person is not willing to go on and take the whole course and like I said, it's going to be very long, it will probably take the average person about 100 hours to complete the whole thing, which is a lot of time for anybody, especially university research faculty who are trying to teach classes and do the research and get published and all this other good stuff. We'll have very short descriptive technical assistance pieces that anybody can printout and hand it to the person and say this is what you need to do. And the pieces are going to be centered on black board and WebCT and I think on top class so they will be platform specific and obviously we're going to try to work with black board and WebCT to make sure that the information is as current and up to date as possible. We'll continually be updating this over the first three years that it's offered so that nothing that we have is ever going to be obsolete because we wouldn't want that. >> Rachel: Okay, and I would just add to that and say as we've said, Curtis is with the Southeast DBTAC, and I'm with the Southwest DBTAC, even though our name is Disability Law Resource Project and there are ten of these DBTACs or ADA and I. T. accessible information centers around the country. And all ten of these DBTACs are working on helping and guiding educational entities on making their information technology accessible. So if you are looking for some additional technical assistance, I would encourage you to call. There is a single 800 number that will connect you wherever you are in the country, that will connect you to your regional DBTAC. And each of the DBTAC's have different projects going on and different resources within their region. So in some regions you might find somebody who can come and provide your university with some training. In another region you might find additional material. You know, you might find people who can coach someone over the phone. So there is some additional technical assistance. Though of course what the Southeast DBTAC is working on is very comprehensive. In the meantime, there certainly is additional help for you. So let me just throw out that 800 number. It's 800-949-4232, and that's voice and TTY. >> Curtis: And additionally, two other good resources -- first of all there is the national center on accessible information technology and education that's out of the University of Washington. They're partnering with all the DBTACs to provide technical assistance information. I don't have their phone number, but their website is WWW.Washington.edu/accessIT -- additionally, in terms very section 508 comply arpx it's more towards government and industry. Here at Georgia Tech there is the information technology technical assistance and training center. They are another valuable resource. Their website is WWW.ITTATC.org. >> Rachel: Great. And all of the links that Curtis has been mentioning throughout the call, I will go ahead and post on our website, the place where you went to tune in to this web case. So that will be up there. Okay, let me see the other questions I've got in. Let's see, okay, can Curtis please comment on how current copyright laws such as the digital millennium copyright act and the teach act impact distance education? >> Curtis: No, I can't because I don't know a thing about either one of those. I'm very sorry. Really, I am. I have taken zero copyright law. I have absolutely no idea. Obviously the copyright issue is going to be problematic for accessibility for two main reasons. First of all is that there is an ongoing question about who's got the copyright to the information, whether that's the information or the professor who's actually generating the content and then there is the question of whether or not if the information is available in an accessible online format, whether or not that information can get out. And that's really a question for the different courseware companies to address in terms of security. The other thing is you have the issue of academic freedom, and professors, especially those who have tenure, simply are going to have a certain degree of reluctance to put the information online and then once it's online, they're reluctant to make any changes because they believe -- they do -- in the concept of academic freedom in the right of a professor to teach a course any way that they want to. So there is really going to be some substantial intersection between copyright and academic freedom and ADA and Section 504 and section 508. In terms of copyright I'm not able to answer any questions simply because I don't have the background in that field. >> Rachel: Okay, thanks. This one you can definitely answer. >> Curtis: Oh, good. >> Rachel: This person read in the handouts that the Southeast DBTAC is or will be working with MERLOT in creating voluntary standards for their faculty materials. >> Curtis: Right. >> Rachel: Is this a current partnership and can you talk a little bit about it? >> Curtis: I can. That's actually in the third year of our grant proposal. The proposal covers three years. The first year will be the module and the pilot course here at Georgia Tech. The second year we're going to be putting the modules, the tutorial, into action. We're recruiting Georgia Tech faculty to come in and take the course. We're giving them a stipend to do that, and we're going to be tracking them to make sure that the online courses that they put out are going to be accessible. The challenge there is that -- Georgia Tech's engineering school, a lot of the courses are going to be engineering classes and what we told the Department of Education is that if you can make a mechanical engineering class accessible for someone who is blind, you could do pretty much anything. Because it's going to be really, really hard to get these courses to be completely accessible, simply because they use a lot of math. They use a lot of visual concepts, just all sorts of different things. I don't even know what all is going to be involved in doing this because we're just now being able to recruit the professors. Then the third year of the project we'll be working with MERLOT. And they don't have anything to do with (Inaudible). Some people are going to be disappointed about that and it's an acronym and I can't remember what it stands for, Multimedia Educational Resource for Learning and Online Teaching, something like that. I can't tell you exactly what it is because I don't have access to a PC right where I am. What MERLOT is, it's a collaboration with the University of California system, University of Georgia system, University of North Carolina system and the University of Oklahoma system to put together a series of modules. These are modules that are peer-reviewed, in other words, another university professor has had a chance to look at them. They are modules that are available online and that anyone can use in a distance learning environment, in other words, a professor can say for this assignment, I want you to go to the MERLOT database and pull out this module and follow the instructions there. And it's a way for people to use outside resources to build up these distance learning courses. However, a lot of the information in the different modules is not accessible. MERLOT does not have as part of their peer-reviewed system any way to check on the accessibility. What we are going to do in the third year of our grant, and that will start in October 2005, is to go into MERLOT, work with them to develop standards, develop ways to look at the peer review in terms of accessibility. To review the information that's on the database and determine what's accessible and what's not accessible so that when you go to the database and you can look for material that is accessible and include that in your course. But if you go to the MERLOT website, you can search the database. You can see the kinds of things that are available. And the idea is that eventually, everything in the database will either be accessible or have something that tells you why it's not accessible, and that's something that's a couple of years off. We're going to be real happy to work with them. We've already started talking with them a little bit. I spoke at their conference last year in Atlanta and they're really excited to be on board. >> Rachel: Okay, great. All right, I am getting a request from the captioner that you need to slow down a little bit to help her get through these last few minutes. >> Curtis: All right. >> Rachel: I have a couple of questions here. I'm going to sort of paraphrase because they're related. Basically, it comes from either students with disabilities or, let's see, disability student services coordinators, and they're trying to get a sense of how the decisions regarding the designs of programs and accessibility are made and what kinds of arguments and strategies can they use to make sure that students -- that universities are proactive as well as reactive to actually accommodate individual students with disabilities? >> Curtis: Well, in terms of the providers, black board and WebCT, I think that that battle is being won and in the new versions it may already be won. I think that they didn't address it at first. That they started to get complaints and they're worried about their possible exposure in cases of any litigation, and I think that they have decided that they are going to take the steps they need to to make sure it's accessible. Whether they achieve that or not, I don't know because I haven't seen the new versions. I know they have people on staff who are concerned about this, but they're kind of in the same boat with Microsoft and IBM and macro media and Adobe and all these leading software companies out there where they know about the issues. They're trying to address them, but they may not always be completely successful. In working with individual faculty members, you've got a situation whereas a student with a disability or as a disability services provider, you may not have all the technical knowledge that you need to determine whether something is accessible -- you can determine whether something is accessible, but to determine how to fix it, you may not know, and the faculty member more often than not is not going to know. So it's a situation where everybody needs more information than they currently have to determine what needs to be done to make sure that an individual course is actually going to be accessible. In terms of strategies, obviously there are things you can talk about. You can talk about ADA. Can you talk about effective communication. You can talk about the needs of an individual student. What's going to be effective really is going to be -- is going to be what is going to rest oh Nate most with that individual professor and it's really a case by case thing. There are some people or professors or faculty or teachers or whatever who are going to be sympathetic and some who are not going to be. There are some who are going to be sensitive to possible complaints of litigation. There are others who are not -- it's like with any other kind of accommodation. There is not any magic words that I can tell you that's going to convince an educator or a campus to provide complete accessibility, especially when the people who are involved really don't have a good handle on what they need to do. >> Rachel: And can you instruct students a little on when their requests are denied, how they should proceed? >> Curtis: And again, that is that individual -- if the requests are absolutely flatly denied, obviously you've got the right to file a come mraipblt, and that can be with the Department of Education. The other issue there is that a lot of the times that your regional OCR office may or may not have the technical knowledge themselves to determine whether things are accessible or not. It's not a knock on them. It's just that it takes -- you know, pretty much anybody can look at a building and say whether it's accessible or not. You kind of have to have a good knowledge of the issues involved to look at a document to determine whether it's accessible or not and you have to use the different evaluation tools that are available. It's not the same as building accessibility. So certainly file a complaint. The other good option would be to work with the people, the stakeholders at the university, at the provost's office, if that's where the I. T. is centered. A lot of places it is. Somebody gave me a pecan before I went on and it stuck in my throat. >> Rachel: You'll have to hunt down that person as soon as we get off. >> Curtis: I'm going to have some words with this person. The best system that I've seen used myself is what was done at the University of Texas. The provost decided that we're going to have a policy that all of the U.T. websites are going to be accessible. Since this is a DBTAC call I can say U.T. and people won't think University of Tennessee. The University of Texas worked with a nonprofit. They're out of Austin, and they put together an accessible Internet rally at the University of Texas. And they had a competition between the different departments as to who could design the most accessible website, and it succeeded and in fact a research survey that access I. T. has done recently, my understanding is that the University of Texas and the University of Texas in Arlington were two of the best campuses nationwide in terms of accessibility, and it only happened because you had really some high level buy in from the provost's office and you had some imagine that tif competitive way to get people to comply. And we're actually trying to borrow that in the project we're working onto get some of the Georgia high school websites to be more accessible. So that's one option. I think high level buy in at universities is just absolutely necessary to make sure you get some action. >> Rachel: Yeah. And I just want to mention to people with the no built, our agency will be working with them to do an Internet rally in Houston shortly. So if you're interested in more information about that, go ahead and give us a call. I'm going to try to squeeze one and maybe two more questions in really quickly. >> Curtis: Okay. >> Rachel: Okay, if certain A. T., assistive technology products work with a particular program and others don't, can the instructor or the university require a student to use different A. T. products? >> Operator: Excuse me there, are only five minutes left before your scheduled conference will end. >> Curtis: Well, that's a possible accommodation and the answer to that is if you're going to require a student to work with a certain type of assistive technology, then the next question is do you have a responsibility to buy that technology for a student? And the question is, is it going to be cheaper in terms of a university to buy this A. T. for this one student rather than to make the entire course accessible for people with all kinds of disabilities. And under ADA, I think that if you're willing to provide the other alternate A. T. and also whatever training the student might need as an alternate accommodation, I think you're probably within your rights to do that. >> Rachel: Okay. I know we have I think literally four minutes left. Curtis, are there any additional comments or wrap up comments you'd like to make? >> Curtis: The one thing that I would advise anybody to do who is interested in this field is to kind of keep track of the different legal developments. We're going to get more litigation in this area. We're going to have more lawsuits, and we're going to have more court decisions. And things are going to change. I think things have changed because we had the southwest airlines website, not for the better necessarily, but the legal environment is changing so fast you've got to try to keep up. And follow the news to the extent that is usually -- this kind of thing gets reported pretty well and just try to stay on top of current events as best you can. >> Rachel: Right. And a lot -- I know that our DBTAC and I believe a number of other DBTACs have some electronic news bulletins that are put out that can keep you up to date on this legislation. So if you're interested in joining those, go ahead and shoot us an E-mail. So okay, I think we're ready to wrap up. Thank you so much, Curtis. You really were able to give us a lot of information in only an hour and a half. Although it probably seems like two and a half hours to our captioner who is fabulous. So I have a couple of additional thank yous before we sign off. I would like to acknowledge the support of NIDRR who funds DLRP and makes the sharing of this information you've heard today possible. >> Curtis: They fund us, too. God bless NIDRR. >> Rachel: That's right. Amen. I also want to thank the ILRU team who really work hard to make these productions possible as well. They include Dawn Heinsohn, Sharon Finney, and Marj Gordon. As well as we have Rob Dickehuth who is the one who connects us to the Internet, and our unflappable realtime captioner Marie Bryant. Again, Curtis, thank you so much for today. I think everybody has learned a lot from this and we appreciate your taking time to do this. Do you have anything else, Curtis, before I sign off? >> Curtis: Thanks to the audience. I appreciate all the questions. Thanks to the ILRU folks. Thanks to NIDRR and the Department of Education, and if you have any questions, call your local DBTAC at 800-949-0232. >> Rachel: Thanks for joining us today. Bye-bye.