#86 You Already Agreed to This: Digital Accessibility as Civil Rights with Ray Rose

# Why Distance Learning — Transcript
## Guest: Raymond Rose
## Cohosts present: Seth Fleischauer, Allyson Mitchell

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### Timestamps are recalculated approximations

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## [INTRO — recorded separately] [00:00:00]

Hello, and welcome to Why Distance Learning, the podcast for education leaders and practitioners who are making real decisions about how virtual learning gets designed, adopted, and sustained. I'm Seth Fleischauer, founder and president of Banyan Global Learning, and my cohosts are Allyson Mitchell and Tami Moerhing of the Center for Interactive Learning and Collaboration. Every episode we try to surface at least one assumption worth questioning.

Raymond Rose is President of Rose & Smith Associates and Public Policy Chair and Digital Accessibility Liaison at the Texas Digital Learning Association. He co-directed the Virtual High School at the Concord Consortium in the late 1990s and wrote the nation's first virtual school Special Education Policy. He's been making the case for digital accessibility ever since. The assumption on the table today: accessibility is something you provide when a student with a disability enrolls and asks for it. Raymond's work suggests institutions have already committed to full accessibility by signing the non-discrimination agreements attached to their federal funding and state certification. Most of them just don't know they're already out of compliance.

*This episode is brought to you by CILC, the Center for Interactive Learning and Collaboration, connecting students to real experts through live virtual field trips and experiences — visit cilc.org to learn more. And by Banyan Global Learning, which brings K-12 classrooms face to face with global peers and expert facilitators through live, thematic international exchange programs — find them at banyangloballearning.com.*

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## [Recording begins]

**Seth (00:00)**
Ray, welcome to the podcast.

**Raymond Rose (00:02)**
Thank you. Looking forward to it.

**Seth (00:05)**
So you came our way through Michael Barber — someone who's been on the podcast now three times because one and two was not enough. It came out of me attending DLAC a while ago, and meeting him, meeting Jared Borup, Bobby Sanders, some of these people who've been on the podcast since then. Your name also came up as part of the DLAC report, of which there were

**Allyson (00:13)**
You

**Raymond Rose (00:20)**
Mm-hmm.

**Seth (00:32)**
I don't know, 20 of you, 25 of you — that Michael Barber was the editor trying to collect all of this. I could see him being effective at that job. And yeah, we are trying to get as much institutional research-based knowledge into the conversation as possible.

**Raymond Rose (00:34)**
Twenty-five. Herding cats. Herding cats.

**Seth (01:00)**
And you have your corner of the field that you've been focusing on for a long time. How would you describe that? How would you describe what your contribution to the body of literature around distance learning, virtual learning? Where are you coming from? Who are you in all this?

**Raymond Rose (01:17)**
So if I'm going to use an official title, it's digital learning evangelist, just as a starting point. But I also will say professional troublemaker. And yeah, you know — it was Representative Lewis, I guess. I've got a t-shirt. Make trouble, good trouble.

**Allyson (01:24)**
Yes.

**Seth (01:29)**
Good trouble.

**Allyson (01:29)**
Yeah.

**Allyson (01:45)**
Yes!

**Seth (01:47)**
Mm-hmm.

**Raymond Rose (01:47)**
And that's what I like to do. Because there aren't a whole lot of people focused on digital accessibility. And so I'm always pushing, and I'm pushing towards the legal compliance side, and that presents some interesting conflicts for some people.

**Seth (02:10)**
And so you've been making this argument that digital accessibility is a civil rights obligation, right? And so when you're talking about the letter of the law and compliance, that's the angle that you're coming from — this is grounded in agreements that institutions have already signed, have already committed to, right? And so it is a compliance issue, not a matter of policy. And you've been doing this for decades now. Can you paint a picture of what has actually changed in that time?

**Raymond Rose (02:17)**
Right. No.

**Raymond Rose (02:29)**
Yep. Right. Yeah. Yeah.

**Seth (02:40)**
In the time that you've been focusing on this.

**Raymond Rose (02:41)**
So let me tell you a story. It goes back to when I was a civil rights specialist for the Mass Department of Education. And at that point, some districts had been cited in their special needs reporting — they had a significant number of minority students in certain categories. So I went to meet with a superintendent and said, okay, so here's the citation, and here's the data you submitted. We're concerned about it. And the superintendent said, you know, when we filled out the form, we asked people what they thought we should have in these categories. And so that's the data. We can't replicate anything that we said. And I'm afraid that superintendents sign their non-discrimination statement not really thinking about the implications for it. So it's there and it's clear.

In terms of the feds, you look at the compliance statements that people are signing — they have to comply. But did anyone tell people about that? No, they just signed. And I will point back to state certification requirements for teachers and administrators, because until we can get them to change the certification requirements, the issues of accessibility get buried. They're not required. And until we can get people to pay attention there, we're not going to have the broad attention that we need. So we've got a number of people who believe in civil rights issues, pay attention to it, tell their teachers that they need to comply.

**Raymond Rose (04:37)**
Schools have had a 504 coordinator since 1973, basically. 504 came in, required there would be a 504 coordinator. That role generally falls to a special needs director or somewhere in the special needs department because 504 — there are 504 plans that schools create to provide services to students with disabilities.

But where do they get the 504 training? I have yet to see 504 training in an institution of higher education in their education programs. It may get mentioned somewhere as just a statement. They don't know about 504 as it relates to the web situation. There are basic requirements for a 504 coordinator. Number one, that you notify everybody annually who the 504 coordinator is, and that there be a 504 grievance plan. It can be the same as the district's other grievance plan, but they need to say it's for 504. I've got school districts where I can't find a listing for a 504 coordinator when I go and look. So compliance is not

**Seth (05:58)**
Mm.

**Raymond Rose (06:04)**
universal, is not general. And in many cases the school districts believe that they have contracted out a website — the website provider says we're going to make everything fully accessible. And I've been on some of those websites and I know they're not fully accessible and that there are very basic accessibility issues that are in violation.

**Seth (06:29)**
So I hear the deficits here. And obviously this is the stuff that you're working on, right? These are positions that need to be named, they need to be trained. The difference between "you need to comply with this" and "you need to comply with this in order to be able to renew your certification" — that's something you're working towards.

**Raymond Rose (06:35)**
Yeah, yeah.

**Raymond Rose (06:55)**
That would be nice. Yeah, right. Yeah.

**Seth (06:56)**
Yeah. I mean those are the teeth, right? That's the teeth of any compliance. But has this gotten better over the course of the time that you've been working on it? Give us something hopeful here. How has it gotten better?

**Raymond Rose (07:07)**
Yeah.

Well, it's gotten better because there are a few of us that are out there doing workshops and spreading the word.

**Seth (07:23)**
So campus by campus, they're

**Raymond Rose (07:24)**
Campus by campus, well, you know, okay — DLAC. You were at DLAC. It was probably the most recent one. If it was in Texas, I went to it, but if it was not in Texas, I didn't go to it. We do workshops. We've got multiple people now doing workshops, doing sessions, talking about accessibility. And that spreads the word.

**Seth (07:38)**
Yeah.

**Allyson (07:38)**
You

**Raymond Rose (07:55)**
I'm part of TxDLA, Texas Digital Learning Association — public policy chair, but I'm also the digital accessibility evangelist there. And we have been doing courses for the past five or six years on digital accessibility. Now, generally we have higher ed people, not K-12 — we're getting a smattering of K-12 people. But you get somebody trained, they go in and figure out how to advocate

**Allyson (07:58)**
Yay!

**Raymond Rose (08:24)**
in their institution. The problem with K-12 and higher education right now is getting people at the highest level to say yes, we want to do this, this is important. And that's the struggle right now — trying to figure out how to get their attention. And I've got probably two writing projects that I need to do in the next month in preparation for school openings to address some of those issues. But the real focus is just getting the word out that people need to be thinking about more than just putting something together.

And you know, I'm gonna play a little bit. Your topic is Why Distance Learning — and I told you I was gonna give you a hard time on that one. It should be Why Digital Learning rather than distance learning. You know, we're not talking about the Pony Express anymore.

**Seth (09:23)**
Mm-hmm.

**Raymond Rose (09:23)**
Using the Pony Express and sending books through was distance learning. And we've moved significantly along from that. So digital learning would be my preference there. And Texas — Texas Digital Learning Association used to be Texas Distance Learning. And we changed the name to be reflective of where we are today.

**Seth (09:47)**
Mm.

**Allyson (09:54)**
I am just for fun — I love the distance learning term, but I am a museum person, I always say. So the history of how distance learning has evolved, I can always say to clay was the technology at the time. Just in case anybody needs to know, there's a framework.

**Raymond Rose (10:01)**
Mm-hmm.

**Seth (10:08)**
Yeah, you may not be talking about the Pony Express, but we are.

**Allyson (10:22)**
Even if it's not in practice right now.

**Raymond Rose (10:24)**
Yeah.

**Seth (10:27)**
Allyson, did you wanna go to that question?

**Allyson (10:28)**
Sorry. Yeah. I was just thinking about, you know, I love nomenclature. I love talking vocab in the sphere of digital learning and virtual learning. It's always so fun. But I did want to know a little bit more as a concrete example of accessible — because I think it's so interesting what you're talking about, because it really shows digital isn't always as tangible as something that you can touch and feel. So if somebody is thinking about what does this look like in practice?

**Raymond Rose (10:51)**
Yeah.

**Allyson (10:57)**
Can you share the difference between what would pass — a course that passes versus one that wouldn't? Or maybe that's still being developed.

**Raymond Rose (11:03)**
No. No, let me let me give you a specific piece. This is a quote that I use in some training, and it's from the US Office of Civil Rights' operational definition of accessibility. That those with a disability are able to acquire the same information and engage in the same interactions

**Seth (11:05)**
Yeah.

**Raymond Rose (11:33)**
and within the same time frame as those without disabilities.

The key for me is same time frame. That when you start thinking about doing things online or in a classroom, you've got a group of students. If one student has to use a screen reader, for example — do I need to define screen readers here?

**Allyson (12:03)**
You can, just for anyone that's listening that may not know.

**Seth (12:04)**
Sure, go for it.

**Raymond Rose (12:04)**
Okay. So a screen reader is a technology that will enable somebody on a computer screen to read text — it speaks the text so that they can hear it. Well, that's great. But you have to make sure that what is on the screen can be read. And one of the big problems in higher ed, and I suspect in a lot of K-12 websites, is they will do something called a PDF. And PDFs come in two basic flavors, and one of them is a simple picture. A local school district that I was looking at — in a different state than where I am — had a student dress code document. It was a PDF that could not be read. So from my perspective, it was a worthless piece of information. Okay, maybe they don't have any students that have screen readers, but they expect parents to be able to get there. Do they know how many parents are using screen readers? They have, by design, made this product not fully accessible.

And so what's the difference? The difference is that you pay attention to people with disabilities. There are specs, there is guidance. One of the things I talk about is Universal Design for Learning. We know about universal design, the curb cuts and all that. So applying it to learning is thinking about how to make the learning more broadly helpful. And if you make a course following Universal Design for Learning principles, it's

**Allyson (13:43)**
Yes.

**Raymond Rose (14:04)**
may not be perfectly accessible, but it's going to be a whole lot more accessible than somebody who just throws together course content without thinking about the issues at all. So Universal Design for Learning — that's a model to look to. And we're training teachers to do that now. But go ahead.

**Allyson (14:19)**
Yeah, that's the model to look to. Yes.

**Seth (14:23)**
Yeah. And that's

**Allyson (14:26)**
Yeah. And could you break down Universal Design for Learning? Because it's three different components, right? It's the three different parts of your brain that are stimulated at different points of the learning experience, correct?

**Raymond Rose (14:41)**
So there are, yeah, three components to universal design: multiple means of engagement, multiple means of representation, multiple means of action and expression. And if people are looking for more details, they should go to cast.org, because they are the national headquarters for Universal Design for Learning, at least in K-12.

**Allyson (14:49)**
Mm-hmm.

**Allyson (14:53)**
Yes.

**Allyson (15:11)**
Great, we can link that in the show notes too. I always remember Universal Design for Learning because of the models where it's the brain and there's three different colors. So that's always something that just always brings it up in my mind.

**Raymond Rose (15:20)**
Yeah. Yeah. And so we're

**Seth (15:26)**
Sounds like you had multiple means of representation when you were learning that. Yeah.

**Allyson (15:29)**
I did, I did. And then you get to apply it to museum collections in a virtual space — you're like, where am I? There's so many different framers.

**Raymond Rose (15:29)**
Yeah.

**Raymond Rose (15:35)**
Yeah.

**Seth (15:39)**
So, Ray, that's one of the arguments here in terms of building accessible content in the digital realm — that if you design for people with disabilities, really you're designing something that's better for everybody, right? Like using something like Universal Design for Learning. But there's also the argument that people learn differently and they need information presented in different ways. That would be more towards what you were talking about first in terms of the compliance.

**Raymond Rose (15:54)**
Right. Yeah. Yeah.

**Raymond Rose (16:05)**
Which is — which we're talking about universal design. As soon as you start saying that, you're talking about Universal Design for Learning. That's the whole point, that you have multiple options for students so that it can fit best within their needs and their learning style. Although — learning style — we shouldn't say, I shouldn't say learning style. That's a bad word.

**Allyson (16:08)**
Yes!

**Seth (16:08)**
Sure, sure.

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*[CUT A: Learning styles tangent removed — 16:27–17:48 original]*

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**Allyson (16:27)** *(approx)*
And it's interesting to think about digital accessibility, because especially when we walk around in what some could argue is an able-bodied world, you're not always thinking about what somebody might be living with. So I do wonder if there's any consistency in the digital accessibility that you see as a constant stall — that there's constantly this problem that you

**Allyson (16:49)** *(approx)*
have been providing remedy to. So Universal Design for Learning sounds like one of those remedies, but is there something that you see often that you're like, hello?

**Raymond Rose (16:52)** *(approx)*
No.

**Raymond Rose (16:59)** *(approx)*
There are a few of those. But both my learning and — I think people — when I'm doing training, I use a model that actually my wife came up with about picking weeds. Do you have a garden? Okay. And do you pick the weeds out? Yeah, okay. Good response.

**Allyson (17:18)** *(approx)*
Yes.

**Seth (17:18)** *(approx)*
I do.

**Allyson (17:22)** *(approx)*
I was gonna say this.

**Seth (17:22)** *(approx)*
Occasionally — it depends on if they're pretty or not.

**Raymond Rose (17:29)** *(approx)*
And so you pick out the weeds, Allyson and Seth, and then you go back the next day and you see more weeds. You picked out the ones that were most visible. And then you discover that there are more. The learning about accessibility is sort of the same way. And it's, you know, I started off with it saying, okay, the thing that we need to do is get captions on videos. And when I started pushing that, we didn't have the automatic captioning systems that we have today.

And so it was interesting — I was the director of a Department of Education project where we were doing online teacher professional development and we had videos, and I had to find somebody who could caption them. And that was not an easy effort. I ended up at the GBH Captioning Center. They did the captioning and then they were using what they had done with us as models, as we're trying to get people to understand captioning.

And I would show a group of people two videos, one that was captioned, one that was not. And the captioned one got a much higher response — people understood what was going on more. When I do training, I generally ask how many people use closed captioning on their TVs. That's our norm in our household. And I will generally find that twenty-five to fifty percent of the people in an audience are using captioning on TVs. Why are we not using captioning for classroom instruction on videos? So that's a big one. It's a visible one. And today you can take

**Seth (19:25)** *(approx)*
Pick that weed.

**Allyson (19:28)** *(approx)*
Yeah.

**Raymond Rose (19:28)** *(approx)*
Yeah, yeah. But it's a relatively easy one, because there is such good automatic captioning. It used to be that some of the services would say we're captioning, but we're doing it at like seventy percent accuracy. Well, seventy percent accuracy is not accessible. But you know, you're shooting for a hundred percent. You're not gonna get that necessarily unless you've got people sitting there doing the actual transcript work on it. But 90% is better than 70%, and it makes a big difference.

But that's sort of one of the easy visual ones. One of my other simple ones is 25% of males are colorblind.

**Seth (20:18)** *(approx)*
Hm. Really? Twenty-five percent? Wow.

**Raymond Rose (20:20)** *(approx)*
25% of males have some form of colorblindness. So designing a course — and I used to do when I was talking about some of these things, I would have one of the colorblind test things as an activity. And I got done with the session, and one of the people in the session came up and said, My son is colorblind, and I'm an instructional designer, and I've never thought about the colors that I use for design.

And part of it is the awareness — just expanding that awareness so that you don't have two circles, one is red, one is green, and you tell people pick the circle. Well, if you're colorblind, you can't necessarily tell the difference there. But if you have a red square and a blue circle, that works. Because you can say, pick the object, and that helps. So there are things like that that happen.

The most common findings when people do compliance reviews is lack of alternative text in graphics. If you have a graphic — now the systems will ask you about producing a description for alt text. That didn't happen five years ago. Didn't happen two, three years ago in general. It's a new thing that's happening. But people throw a graphic up and they should be doing the alt text, which is for the screen reader. The screen reader comes along, and if there's no description, it says "graphic." That doesn't help anybody.

Thinking about why you are using this image — is it just a decorative image? Then the screen reader can ignore that. You say "decorative image," drop it off, screen reader ignores it. But if you've got a picture — the AI systems are great at describing the picture, but not necessarily in the context that the teacher is using the picture. So they need to go back and think about why they're using that particular graphic, what the point is they're trying to make.

**Seth (23:31)** *(approx)*
Yeah, which is a good metacognitive exercise for a teacher to go through when they're including a graphic in their lesson design, right? Yeah.

**Allyson (23:45)** *(approx)*
Yeah, and using AI as well to help build up the lesson — to ask the question of is it in the right context in which you're going to be utilizing it.

**Raymond Rose (23:45)** *(approx)*
Right. Yeah.

**Seth (23:55)** *(approx)*
You cited a lot of examples there that are technologically aided. Are there other developments that have happened in the last several years — with AI, but even before then — that have made this work more accessible? See what I did there. For teachers to employ when they are designing lessons, performing lessons — what are some of the big tech breakthroughs that we've had?

**Raymond Rose (24:11)** *(approx)*
The big one I think is the captioning piece. The other is being able to look at your digital resource — whatever it happens to be, your website — and have a tool that goes in and identifies the issues that need to be fixed, where the problems are.

**Seth (24:47)** *(approx)*
Mm.

**Raymond Rose (24:52)** *(approx)*
And I've got a number of tools that I use just for fun that will go in and look at a website. They claim to be twenty-five to forty percent accurate — they're gonna miss the greater majority of issues. But this goes back to when I was a civil rights specialist: if they can't get the basics, they're not gonna have the big issues taken care of. It's like if I'm going in looking at a school district and looking for the information about the 504 coordinator, and I can't find it, and I can't find any grievance process, and I can't find a notification — I expect that they don't know a whole lot about 504 broadly, because they haven't been able to get the basics. And that becomes the flag. Look at the basic information that's easy.

**Allyson (25:40)** *(approx)*
Mm-hmm.

**Raymond Rose (25:52)** *(approx)*
And if they get that good, then you can expect that at least the easy stuff has been taken care of. So yeah — alternative text, documents posted in formats that can't be used, lack of captions on videos. And then you get into things like data tables. People use tables, and especially if you're doing writing and you want to organize it — they take and use a data table for writing, which is wrong. It's wrong. Learn how to do the things in Word, not using data tables, because a screen reader is going to come along and see a data table. And then it's going to be confused because there's not the right data in the right places because people haven't organized the data table the way it should be done for accessibility. If you're going to use a data table, use the accessibility tools built in to help you design a data table that works right.

**Seth (26:57)** *(approx)*
It's like the green M's. Yeah.

**Allyson (26:59)** *(approx)*
Yeah.

**Seth (27:03)** *(approx)*
A practical question for a teacher who is using AI and LLMs to try to improve the accessibility of a given lesson plan — would they just put it into an LLM and say,

**Allyson (27:30)** *(approx)*
Yeah, that I was thinking.

**Seth (27:32)** *(approx)*
make this ADA compliant? Or is there a more sophisticated prompt that you would recommend?

**Allyson (27:36)** *(approx)*
Yeah, that's what I was thinking the same thing. Like, how can we check our work — what's the best way to ensure that you are thinking about accessibility? Just even the table had me thinking, what is the best way that the data table should have the alt text?

**Raymond Rose (27:58)** *(approx)*
Yeah. So the starting point — as more and more tools have accessibility checkers built in, you use those. Those are the tools that you're using: Word, Docs, some other tools. Just about everything today has some sort of accessibility check built in. So you start there.

And then most of these things are being put in a learning management system, an LMS. Now the LMSs have the ability to do checks if the entity has bought into that. So you can run an LMS and not have accessibility checks, but if you've been a little bit knowledgeable, you're getting the system that has some accessibility checks. And that runs an accessibility check — they will run multiple kinds. And there are accessibility checks that will look at the videos and see if they've been captioned. It won't necessarily tell you it's captioned at 90%, but the AIs can help with that.

But if you just ask an AI about accessibility —

**Seth (29:27)** *(approx)*
Mm-hmm.

**Raymond Rose (29:28)** *(approx)*
I've done that a few times and I don't necessarily like the responses. One of the things I have fun with is when people are talking about AIs, I ask them, so how accessible is it? And a year ago, people didn't have any idea — they were talking about AI and had no idea what I was talking about when I said how accessible is it. That is changing now.

And you look at the requirements on school districts. They don't necessarily know this, but when they are purchasing third-party products, they should be reviewing those products for accessibility. Now they're probably checking them for cybersecurity reasons. Because when you look at the cybersecurity stuff, the majority of cybersecurity breaches in school districts happen because of third-party products — they come in through the third-party product and then get access to the entire data set that the school district has.

So school districts, before they are purchasing, should be reviewing products for cybersecurity. They should also be reviewing products for accessibility. There are ways to get information. A third-party vendor today should know what a VPAT is. A VPAT is a Voluntary Product Accessibility Template — it's something they fill out voluntarily. But more and more school districts who understand this are saying, do you have a VPAT? Or the VPAT becomes something else called an Accessibility Conformance Report. Too much jargon, but it's VPAT and ACR. You ask the vendor if they've got one. If they don't have one, don't get the product. Don't get the product. Because they don't have the legal requirements that the school district does. And it's not the vendor who's going to be in difficulty — it's the school district for not having things accessible. So it's the school district's responsibility to look at those products, check to see if they are accessible.

**Allyson (31:27)** *(approx)*
You

**Seth (31:30)** *(approx)*
Mm-hmm.

**Raymond Rose (31:53)** *(approx)*
I will tell you that vendors are having interesting problems making their product fully accessible, but lots of vendors are working on making their product as accessible as they can today. Not all of them. Not every vendor.

**Allyson (32:09)** *(approx)*
But now we know how to check too.

**Raymond Rose (32:14)** *(approx)*
That's right. Yes. And it's fun. You go to a conference and you've got vendors there and you say, can I see your VPAT? Do you have a VPAT? And you know, you get marketing people and they say, What's a VPAT? And so you know where you are. Or somebody else will say, sure, and here's where we have it and here's the information. You get very different responses from vendors, but more and more I am seeing vendors who understand the language.

**Seth (32:43)** *(approx)*
Hm. That does sound like fun.

**Allyson (32:46)** *(approx)*
Yeah.

**Raymond Rose (32:47)** *(approx)*
Okay.

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*[CUT B: FCC broadcast tangent removed — 33:10–36:34 original]*

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**Seth (31:49)** *(approx)*
Ray, we have a question that we ask everyone on the podcast. It's the title of the podcast, but we're going to adapt it for you. Ray Rose, why digital learning?

**Allyson (31:56)** *(approx)*
Guess!

**Raymond Rose (32:02)** *(approx)*
Why digital learning? Why not digital learning is a starting point.

Back thirty years ago, I was the director of an NSF project — we were doing online teacher professional development. This was at the Concord Consortium, an educational technology research and development company. And we had a meeting, as you do — these group meetings over time. And you say, so what are the things we want to do next? And I said, we've got enough experience with online professional development. We should be creating a virtual school. I started doing research to see what it would take to do a virtual school. And at the time, accreditation required a library — a physical library with books. So that says we cannot just create a good virtual school that has some credibility behind it. And then

**Seth (32:58)** *(approx)*
Yeah.

**Raymond Rose (33:13)** *(approx)*
the Department of Education put out an RFP for innovative technology applications. We submitted a proposal for creating a virtual high school. We were doing it as a regional thing, as an add-on, as an extra for school districts. We weren't trying to be a school — we were providing course content for them online. And so that was a change in our approach. A change in virtual schools — it was a knock on the door for crediting institutions. Because they'd ask: what's this new thing? What is it? And all the assumptions people make about online learning, they still exist. So that becomes an interesting problem for us as you go forward with getting things happening.

**Raymond Rose (34:16)** *(approx)*
I okay. Why digital learning? I gotta go back to the question. We started off asking teachers who wanted to participate: what's a course that you've wanted to teach, but never had the ability to teach because you didn't have enough kids sign up? I used to be a school administrator and doing the master schedule before we had computers. I was doing it on cr—

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*[CUT C: False start removed — ~39:22 original: "Cards, you know, and doing the souls thing. Never mind."]*

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**Raymond Rose (34:37)** *(approx)*
Yeah, but you run a course — you have to have enough students. You can't run a course for two students, you can't run a course for three students. And depending on the institution, you can't run a course maybe for five students. But if you have 30 schools — which was what we started off with, or 23 schools, I guess it was — if you could get

**Seth (34:37)** *(approx)*
Moving the note cards around. Yeah.

**Allyson (34:38)** *(approx)*
Yeah.

**Raymond Rose (35:02)** *(approx)*
Just five kids across that were interested in the course, you could teach the course online. And so that was our initial start. And as we started doing that, people looked around and said, we can do things like college courses that you couldn't otherwise do because you didn't have the expertise. You know, you don't have the teacher with the credentials, you don't have things. So there are lots of places where this has happened.

In Louisiana, they were trying to get all students to have ninth grade algebra. They didn't have enough teachers certified in math to teach ninth grade algebra. So they created an online program where they would provide the course to the students. The students would sit at computer stations doing the course. But getting algebra — there was a teacher who would be monitoring them that would help — but it addressed a need that people had. And now we're getting more and more options.

---
*[CUT D: Supercomputing anecdote removed — 41:30–42:08 original]*

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**Raymond Rose (36:37)** *(approx)*
And when you start thinking about it, the ability to reach — and I've seen more high tech programs that are being taught in high schools and even down into middle schools now — with online learning. And you talked about there are different approaches for students. I mean at the very beginning we were talking about does every student need the same learning approach? Online learning is an option for them.

**Seth (36:37)** *(approx)*
Mm-hmm.

**Raymond Rose (36:39)** *(approx)*
And it has to be well designed. I'll start off with that. There are people who think — well, let's go back to COVID. And we had — what we don't refer to as online learning most of what happened during COVID. We talk about it as emergency distance education or something.

**Seth (37:04)** *(approx)*
Yeah, right. Yeah. Preaching to the choir here. Yeah.

**Allyson (37:05)** *(approx)*
Experiences.

**Raymond Rose (37:09)** *(approx)*
So we saw people who were doing things — they were just taking what they had been doing in the classroom and trying to replicate it in Zoom. And, you know, we don't have to go through all the details, but that's not high quality education. It's not high quality online learning. It's not high quality digital learning. There are standards. Has anybody talked about the national quality standards? This podcast?

**Allyson (37:41)** *(approx)*
Yep, I was gonna say don't worry, we can link to them as well in the show notes.

**Raymond Rose (38:07)** *(approx)*
Okay, so I don't have to say much more than that, and Allyson can put a link in the resources. Because those exist for a reason. And the reason actually comes back to when we created the Virtual High School — we created a set of standards. How do you measure what's going on in an online classroom? We needed to have some sort of clarity in terms of what the expectations were. And in our model, it was all asynchronous. So we had the opportunity to look at what people were doing, figure out how they were doing it. And to put together standards so that when you tell people, hey, that's a great course, there's a reason we can say that. And so the national quality standards are one. If people want to spend some money, they can do it with Quality Matters, and Quality Matters has training around their standards. So that's another link, Allyson.

**Allyson (38:43)** *(approx)*
Yes. Thanks.

**Seth (38:44)** *(approx)*
I'm working on getting someone from them right now to come to the podcast. But we've had Chris Harrington on, he talks about them a lot. So yeah — it's great to have somewhere to point, right? When this is what it looks like. Well Ray, thank you so much for coming on today. Is there anywhere you would like to point our listeners to find your work online?

**Raymond Rose (38:47)** *(approx)*
Yeah, good.

**Raymond Rose (39:00)** *(approx)*
Yes. Yeah. Right.

**Raymond Rose (39:12)** *(approx)*
Actually, TxDLA — there is a digital accessibility course, so that's a place to go. I created a couple of things and Allyson I'll send you the links on that. But those are

**Allyson (39:31)** *(approx)*
Okay, sounds good.

**Raymond Rose (39:36)** *(approx)*
This was done back in '17, you know, so it's dated. And it's again picking weeds — it's what I knew at the time versus what I've learned and what the technology has enabled. And so it's really a matter of that. I'll give you some other links, Allyson, to the WAVE tool and some other things, and so we'll get those in the resources.

**Allyson (40:03)** *(approx)*
Yes!

**Allyson (40:09)** *(approx)*
Yes, I can't wait. Thank you so much for sending them along and for putting them together and giving us a place to start. Let's centralize those resources.

**Raymond Rose (40:11)** *(approx)*
Yeah.

**Seth (40:15)** *(approx)*
Yeah. Well, Ray, thank you so much again for being here. We appreciate your contributions to the field and for you taking the time to talk to us today.

**Raymond Rose (40:30)** *(approx)*
Thank you for the time. Appreciate it.

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## [OUTRO]

That's a wrap on our conversation with Raymond Rose.

The Office of Civil Rights definition Raymond cited is the one worth holding onto: students with disabilities must be able to acquire the same information and engage in the same interactions within the same time frame as those without disabilities. Same time frame is the clause that tends to catch people. A PDF that's an image, a video without captions, a data table used for layout — these aren't oversights. They're barriers that disqualify content under a standard institutions have already agreed to meet.

Raymond points to the WAVE accessibility checker, the TxDLA digital accessibility course, and cast.org for Universal Design for Learning resources — we'll have links in the show notes.

Thanks for listening to Why Distance Learning, and we'll see you next time.

#86 You Already Agreed to This: Digital Accessibility as Civil Rights with Ray Rose