Regulation

Laymen's Terms

eLearning Application

Yes/No?

Testing Procedures

§ 1194.22 (a)
A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

All graphics and similar visual elements must have a text description that a screen reader can access.  This text is referred to as “alt” (alternative) text. 
Alt text will appear as a rollover on HTML pages.  Websites also have the option of presenting longer descriptions in a “D link”, which appears as a blue, underlined letter D at the bottom corner of the screen.
All audio must have a closed caption transcript.

Audio and graphics are used in almost all eLearning, so these points must be addressed.

Use a screen reader to ensure that all alt text is present and that the reader is able to recognize and read it correctly.
Click closed caption button on every page.  Ensure that the transcript matches the audio exactly.
On websites, roll the mouse over each graphic to confirm that alt text pops up.  (This does not necessarily apply to Flash solutions.)
On websites, look for the letter “D” at the bottom corner of the screen.  Click it to see if additional detailed text appears.
On websites, use a screen reader to ensure that D link text is read.

§ 1194.22 (b)
Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Videos and movies that are presented on screen require both closed captioning of the audio and a description of the visual elements.  These items must be timed to the media presentation.

Some eLearning programs employ videos and movies.  Each solution must be evaluated to see if this requirement applies.

Confirm that closed captioning appears embedded within a movie or movie file.
Use a screen reader to ensure that all descriptions are present and that the reader is able to recognize and read them correctly.

§ 1194.22 (c)
Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Any object or text that uses color for emphasis must also use emphasis techniques that do not depend on color, such as text formatting or descriptions.

eLearning programs frequently contain hot spots, links, rollover states, and highlights that could use color for emphasis.  Each of these elements must be distinguishable by a means other than color as well.

Use a screen reader to confirm that all graphics used as links are indicated to the learner through alt text.
Use a screen reader to confirm that all hyperlinked text is indicated to the learner.
Confirm that all hyperlinked text is indicated by a means other than color.
Confirm that all colored text is also indicated by a means other than color.

§ 1194.22 (d)
Documents shall be organized so they are readable without requiring an associated style sheet.

Style sheets should not affect the ability to read the content on the screen.  If the learner is using a browser that cannot use a style sheet, the learner will still be able to read the content, although it may not appear in the intended font.

Many eLearning solutions include style sheets to dictate the font and formatting of pages.

Delete the style sheet from the course.  Ensure that the content is still accessible.

§ 1194.22 (e)
Redundant text links shall be provided for each active region of a server-side image map.

Each area of the image map must have an equivalent text-based hotspot that is accessible by a keyboard or assistive device.

eLearning occasionally uses pictures as image maps.  Learners are able to click portions of the picture to access additional content.

Use keyboard shortcuts to access each navigation hot spot.
Ensure that navigation and keyboard shortcuts are based upon Windows standards.  Single key navigation should be used unless it interferes with other programming options (i.e. keystroke echo).
Ensure that each hotspot on the image has an equivalent text-based link.
Use a screen reader to ensure that each text-based link is read.
Use a keyboard or assistive device to ensure that each text-based link is accessible.

§ 1194.22 (f)
Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

Server-side maps limit accessibility.  Client-side maps are preferred.

This does not apply to Flash based e-learning.

n/a

§ 1194.22 (g)
Row and column headers shall be identified for data tables.

The headers for rows and columns need to be coded so that screen readers read them in the correct order.

eLearning occasionally presents information in tables.  Each solution must be evaluated to see if this requirement applies.

Use a screen reader to confirm that table elements are read in the correct order.

§ 1194.22 (h)
Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

The headers for rows and columns need to be coded so that screen readers read them in the correct order.  If multiple cells are used as a single header, the coding should indicate to read these together.

eLearning occasionally presents information in tables.  Each solution must be evaluated to see if this requirement applies.

Use a screen reader to confirm that table elements are read in the correct order.

§ 1194.22 (i)
Frames shall be titled with text that facilitates frame identification and navigation.

Each frame within a website should have a title that a screen reader can access to ensure the learner knows which frame is active.

Frames are not recommended for eLearning.

n/a

§ 1194.22 (j)
Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

Content should not cause the screen to refresh at a rapid rate.

eLearning rarely requires rapid refresh rates.  Each solution must be evaluated to see if this requirement applies.

Ensure the screen does not flicker.

§ 1194.22 (k)
A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

If a screen has too many elements to be made 508 accessible through other means, it must have a text only page with equivalent content.  This page should be updated every time the screen is.

This is infrequently an issue for eLearning.  Instructional designers should not design excessive elements for a single screen.

Use a screen reader to ensure the text-only page is read properly.
Have a person who is unfamiliar with the content read the text-only screen to ensure that content is fully understandable without accompanying graphics.

§ 1194.22 (l)
When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

Any content dynamically generated through script must include accessibility information, such as button names and alt text, that is accessible to screen readers.

eLearning often uses dynamically generated content.  Each solution must be evaluated to see if this requirement applies.

Use a screen reader to ensure that all content, including buttons, images, and screen text, is read.

§ 1194.22 (m)
When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

Any plug ins required to access content must be available to the user.
For example, a site that contains a Flash-based solution must also include a link to the appropriate Flash player.

eLearning may require the use of Flash players, movie players, audio players, etc.
Each solution must be evaluated to see if this requirement applies.

Access the course from a computer that does not have Flash 8 and ensure that the learner has access to the download.

§ 1194.22 (n)
When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Assistive technology must be able to navigate through the form and provide assistance to the user when filling out the information.

eLearning frequently uses forms such as multiple choice, multiple select, and fill in the blank questions.  The learner must be able to access and complete answer fields.

Use a screen reader to ensure that all elements of questions are read to the learner.
Use a keyboard to ensure that all questions can be answered without a mouse.

§ 1194.22 (o)
A method shall be provided that permits users to skip repetitive navigation links.

All content must be available without going through the complete navigational path again. 
For example, to access a program in Windows, the user may have to click Start, Programs… etc.  The user could save a shortcut to the program on the desktop or task bar for future reference. 
If a website contains multiple navigational levels to access content, the user should be able to return to that content without going through all the navigational levels again.

eLearning rarely includes complex navigational requirements.  Most programs allow learners to bookmark their exit point, access shortcuts to specific content, and/or use a table of contents or index.

Click table of contents, index, or shortcut entries to ensure they take the learner to the indicated content.
Exit the lesson and re-enter it to ensure that the learner’s page was bookmarked.
Access content using 3 or fewer navigational clicks.  NOTE: This does not include interactions that are designed for linear decisions.
Ensure that the learner can return to previously viewed information without repeating the entire lesson or course.
Ensure that menu selections are no deeper than 3 levels.

§ 1194.22 (p)
When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

If there is a limit on the amount of time the system allows you to be inactive or if a test is timed, then a warning must inform the learner that time is ending.  The learner must have the option of extending the time limit.  I. e. "Warning, your session is about to expire.  Please click here to continue."

Many Learning Management Systems have “time out” settings.  Some may also have time limits on individual questions or entire tests.

Take any lessons, test, or activities that have time limits or “time out” settings.  Ensure that a notice tells a learner that time is running out.  Also ensure that the learner has an option to request additional time.
Click or otherwise activate the additional time option.