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Key Provisions

Effective Date: August 18, 2023
Number: 10
Section: 2
Subject: Key Provisions of Captioning & Accessibility Operating Procedure- Summary

The purpose of this document is to outline the Captioning and Accessibility Operating Procedure for all A-State academic programs. The adoption of this operating procedure requires that all video content used for class instruction is captioned to create greater accessibility, and when video content is deemed essential but captions cannot be provided, transcripts must be made available to students. This procedure ensures that those who are deaf or hearing impaired or those with other related challenges have equal access to learning materials. This procedure is also advantageous for students without disabilities as there are many learning and processing benefits to captioned audio content.

Rationale for operating procedure:
  1. Arkansas State University’s administrators, faculty, and staff are committed to providing a barrier-free environment to every student who has the desire to learn and succeed in the collegiate environment. With this in mind, we have a responsibility to adhere to the requirements of Sections 504 and 508 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act and its amendments. This is to provide reasonable accommodations to qualified individuals with disabilities. Providing captions for all video content used as part of class instruction is aligned with the goals and mission of A-State as well as our legal obligation.
Implementation:
  1. It is most effective to use products with open or closed-captioning or subtitles, whether they are shown in class, assigned outside of class, or utilized for other university purposes. It is the responsibility of all colleges, departments, administrators, faculty and staff to utilize only media produced with open or closed captions or subtitles or provide an alternative format such as a transcript. When a video is shown in class, employees should ensure that captions are turned on, as doing so benefits all students.
New Video/DVD/Film Releases:
  1. It is the responsibility of the college/department, administrators, faculty and staff to:
        • Purchase and use captioned videos/DVDs/films for teaching purposes in their assigned classroom and/or college/department or University-sponsored event;
        • Substitute a video/DVD/film with captioning in the place of an older version without captioning;
        • Update all video/DVD/film stock to include only those with captioning; and
        • Create captions for any University-created video.
Non-Captioned Video/DVD/Film Releases:
  1. It is the responsibility of the college/department, administrators, faculty, and staff to:
        • Transition their media materials into captioned and accessible products for all;
        • Determine if the University or another entity has a captioned version;
        • Seek an alternative video/DVD/film with closed-captioning;
        • Make a determination if the video/DVD/film is essential to a course or if it may be deleted from a syllabus; or
        • Offer an alternative assignment to a student in place of viewing a non-captioned video/DVD/film.
Alternative Accommodations for Non-Captioned Videos/DVDs/Films in Academic Courses:
  1. In the event the college/department, administrators, faculty or staff determine a non-captioned media product is essential to academic course requirements, it is the responsibility of the college/department, administrator, faculty or staff member to meet with the student who is hearing impaired/deaf to determine reasonable alternatives. Access and Accommodation Services staff can facilitate or be involved in that interactive process, if needed. A list of possible alternatives is shown below. This list is not all-inclusive:
        • The individual’s American Sign Language (ASL) interpreter for that particular class will interpret the video/DVD/film, the ASL interpreter will review the media transcript, if available, and/or preview the video. ASL Interpreters must be informed at least two weeks in advance of the assignment.
        • If a captioned video/DVD/film is not available, then the student who is hearing impaired/deaf and the ASL interpreter may be given a copy of the script at least two class meetings prior to the showing. If no ASL interpreter is assigned to the class because the student who is hearing impaired does not understand American Sign Language (ASL), such a student may depend on speech/lip reading and/or the use of an Assistive Listening Device (ALD). In such a situation, when captioning is not available, a transcript of the video should be made available to the student at least two class meetings prior to the showing. It is the responsibility of the instructor to contact the publisher to obtain a copy of the transcript. If a transcript is not available through the publisher, Access and Accommodation Services staff will work with faculty to provide a transcript if given at least two weeks’ notice.
        • The instructor may offer an alternative assignment to the student in place of viewing a non-captioned video/DVD/film. Alternative assignments should be determined on an individual
          basis between the professor and the student who is hearing impaired/deaf. Access and Accommodations staff is available for consultation, if needed. Possible alternatives could include but are not limited to:
            1. Providing in-depth copies of the instructor’s notes on the video/DVD/film to ensure the student is given full access to the main points of the media presentation.
            2. Allowing the student who is hearing impaired to view the video/DVD/film additional times on their own personal time with a copy of the instructor’s notes.
  2. Faculty must note in their syllabus any instructional material or assignments that will involve videos/DVDs/films that are not captioned or for which a transcript cannot be made available. This will allow for adequate notice that a discussion about alternate accommodations will be needed for a particular assignment.
The Role of Access and Accommodation Services (A&AS):
  1. Access and Accommodation Services will provide captioning services for short videos (1 hour or less), provided the material is given to staff in a timely manner (at least 2 weeks in advance). Longer video content should be outsourced to a contracted captioning service. Further, if faculty have more than 3-5 video lectures per course that are 1 hour or less, the captioning service must be outsourced. A&AS will cover the cost of captioning services. Turnaround time for captioning done by A&AS staff is approximately the week before content will be covered in class. If outsourcing is needed, the account for content in need of captioning will be maintained by A&AS. Videos will be uploaded, and returned to the necessary parties as timely as possible.
  2. Priority regarding captioning is given to classes that have or will soon have a deaf or hearing-impaired student enrolled.
  3. If captions on existing materials is needed in a time-frame earlier than what A&AS or third-party captioning can provide, the department/unit will be given resources to have it captioned by an outside company at the department’s expense.
  4. It is the responsibility of A&AS to determine reasonable accommodations, auxiliary aids and services based upon documentation presented by the individual and/or information gathered from an intake session and other assessment. A&AS provides accommodations for eligible students who are hearing impaired/deaf. Below is a list of some standard accommodations. This list is not all-inclusive.
        • Provision of auxiliary aids;
        • Assistance in locating a peer note-taker;
        • Assignment of a qualified American Sign Language (ASL) interpreter.
            1. A&AS will inform professors and instructors when a student who is hearing impaired/deaf will have an interpreter present in their classroom. Notification generally, will be provided within three work days of A&AS receiving a finalized schedule; timely notification is dependent upon voluntary disclosure by the student.
  5. A&AS, in collaboration with the Faculty Support Center, will also provide the University community with general informational materials regarding:
        • Captioned videos and accessible media
        • Working with a hearing impaired/deaf individual & interpreter
Definitions:
  1. Open captioning is a process by which text is added to video or other media that is a written translation of the media’s dialogue. Unlike closed captioning, open captions require no special decoding equipment for viewing on televisions or monitors and are always displayed and cannot be turned off.
  2. Closed captioning is a process where specifically encoded text is placed onto video or other media for the benefit of the hearing impaired. Normally invisible, closed captioning requires an internal decoder to be activated for viewing on the monitor/television.

*Adapted from The University of Texas at El Paso policy and University of Arkansas at Little Rock

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