Development of proposed postsecondary education standards – 2021 initial recommendations report

Letter from the chair to the minister

March 12, 2021

Dear Minister,

The Postsecondary Education Standards Development Committee has completed the first phase of our work on the development of new accessibility standards for postsecondary education. As chair and on behalf of the committee, I am pleased to submit to you our initial recommendations report. I request when this report is posted for public comment, this transmittal memo be included, to help frame our recommendations for readers.

As requested in your mandate letter, and as set out in the Accessibility for Ontarians with Disabilities Act, 2005, in this report we have defined the long-term objective of the proposed Postsecondary Education Standards and each of the measures, policies, practices and requirements to be implemented on or before January 1, 2025, as well as the timeframe for their implementation. Our work was informed by the lived experience of people with disabilities, research, the expertise of committee members, as well as the responses to the survey conducted by the Ministry for Seniors and Accessibility, the Ministry of Education, and the Ministry of Colleges and Universities in 2017.

As you requested, a joint technical sub committee was established, with membership from both the Postsecondary and Kindergarten to Grade 12 (K-12) committees, to consider areas of commonality, with a special focus on transition planning between the sectors. A separate set of recommendations has been developed by that committee, with endorsement from all the Postsecondary and K-12 members. I am pleased to submit that report to you as well.

Through many thoughtful discussions, our committee has chosen to focus our recommendations on the following nine barrier areas that will contribute to making the recommendations successful:

1. Attitudes, behaviours, perceptions, assumptions
2. Awareness and training
3. Assessment, curriculum and instruction
4. Digital learning and technology
5. Organizational barriers
6. Social realms, campus life
7. Physical and architectural barriers
8. Financial barriers
9. General overarching barriers

It is essential that Ontarians, and in particular, the postsecondary education community, move away from a deficit model of disability that views disability as a problem to be fixed. We need to acknowledge that environmental barriers are erected everyday (whether intentional or unintentional), and attitudinal barriers remain the greatest challenge.

We also propose that the Postsecondary Education Accessibility Standards be applied beyond our mandate to include other educational contexts, such as privately funded colleges and universities and transitional job training programs. This will provide continuity and will support students and employees who may be mobile within the postsecondary educational system.

Beyond the individual recommendations, this report is a call to action. The committee understood throughout this process that a socially just society takes an approach that explicitly recognizes and challenges that ableism presents in individuals, institutions and society. When efforts are made to remove barriers, it sends a clear message to the disability community that they are valued and heard. We must now collectively act and demonstrate that we can truly live the values and commitments to persons with disabilities embedded in the Accessibility for Ontarians with Disabilities Act, 2005. It is necessary to move from intention to action to improve recruitment, retention, graduation and employment rates for students with disabilities and most importantly to ensure that students with disabilities are welcome, feel a sense of belonging, and have an opportunity to participate in all aspects of postsecondary education without barriers.

Through these recommendations, we hope to achieve transformational change where there is a shift in the culture of the government, higher education, and society as a whole. The COVID‑19 pandemic gave us the opportunity to challenge our assumptions and conventions. It has forced all of us to work differently and innovate. As a result, the shifts necessary to make education more accessible and welcoming have started. This includes the ability to participate remotely and the application of the principles of inclusive design so that courses are designed with flexibility in mind. We as a society must not return to our pre-COVID‑19 behaviour without applying lessons learned during the pandemic, including the strength of compassion, flexibility, and innovation.

While it will take time for all the barriers identified to be addressed and broadly embedded into the culture of our institutions, intentional inclusion is a collective responsibility and with this, the ability to achieve the recommendations is possible. These recommendations, the existing accessibility standards, and the good work that is already happening at all institutions can move us to a fully accessible province and education system.

It is our hope that the ministry and postsecondary institutions begin making changes before a new regulation is enacted and support the implementation of non-regulatory measures. While we have not assigned timelines to non-regulatory recommendations, we urge that they be implemented as soon as reasonably possible.

It has been an honour to chair this committee and work alongside such passionate, thoughtful and dedicated committee members and ministry staff.

We look forward to receiving public feedback on these recommendations.

Sincerely,

Tina Doyle
Chair of Postsecondary Education Standards Development Committee

Introduction

The Ontario government established two Standards Development Committees in 2017, to make recommendations for new accessibility standards for education, in both the Kindergarten to Grade 12 (K-12) and postsecondary education sectors. The Postsecondary Education Standards Development Committee is responsible for making recommendations to remove barriers in Ontario's publicly funded colleges and universities.

In this report, the committee brings forward for public comment and feedback a comprehensive series of draft recommendations on what accessibility standards for postsecondary education should include. It is the result of the extensive joint efforts of representatives from the disability community and the education sector to identify the barriers that postsecondary students with disabilities face and the measures needed to remove and prevent them.

Background

Standards development and the Accessibility for Ontarians with Disabilities Act, 2005

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) became law in 2005. Its stated goal is the creation of an accessible Ontario by 2025, through the development, implementation and enforcement of accessibility standards that apply to the public, private and not-for-profit sectors.

With the act, Ontario became the first province in Canada and one of the first jurisdictions in the world to establish a specific law with a goal and timeframe for achieving accessibility. It was also the first jurisdiction to legally require accessibility reporting, and one of the first to establish accessibility standards so that persons with disabilities have increased opportunities to participate in everyday life.

The accessibility standards under the act are laws that businesses and organizations with one or more employees in Ontario must follow so they can identify, remove and prevent barriers faced by persons with disabilities. These standards are part of the act's Integrated Accessibility Standards Regulation, O. Reg. 191/11. Currently, there are five accessibility standards that apply to key areas of day-to-day life for Ontarians. These are:

• information and communications
• employment
• transportation
• design of public spaces
• customer service

The AODA requires an independent legislative review every three years to make sure it is working as intended. Both the second and third legislative reviews of the Accessibility for Ontarians Disabilities Act, 2005 (conducted in 2014 and 2019, respectively) emphasized the importance of removing accessibility barriers in the area of education and urged government to consider this a priority area.

Before establishing the Postsecondary Education Standards Development Committee, a survey was developed in partnership with the Ministry of Colleges and Universities and the Ministry of Education in 2016. The survey was conducted to inform potential focus areas for new Education Standards. The survey received a total of 2,988 responses. The survey asked respondents to comment on barriers and best practices in five key areas:

1. accessibility awareness and training
2. awareness of accessibility accommodations (policies, processes, programs)
3. information, communication and inclusive decision-making
4. transition planning
5. inclusive and accessible learning spaces

In 2017, two Standards Development Committees were formed to address barriers facing students: one focused on kindergarten through Grade 12, and another focused on postsecondary education. The committees were asked to work in tandem to address barriers across the publicly funded education system in Ontario.

Mandate of the committee

The role of the Standards Development Committee (the committee) for postsecondary education is to provide recommendations to address accessibility barriers in publicly funded postsecondary education provided by colleges and universities. These recommendations are intended to inform the government’s work on proposed new accessibility standards for education.

To develop these standards, the committee is required to:

• define the long-range objective of the proposed standards
• determine the measures, policies, practices and requirements to be implemented on or before January 1, 2025, and the timeframe for their implementation
• develop proposed standards that the committee deems advisable for public comment
• make such changes it considers advisable to the proposed accessibility standards based on comments received, and make recommendations to the Minister for Seniors and Accessibility and the Minister of Colleges and Universities

The minister requested that the committee:

• develop recommendations to remove and prevent accessibility barriers in publicly funded colleges and universities in Ontario
• work with the K-12 committee to consider areas of commonality, in particular transitions (for example, kindergarten to Grade 12 to postsecondary) through a Joint Technical Sub-Committee

Committee membership

The committee is composed of 20 voting members and two non-voting members representing the Ministry for Seniors and Accessibility and the Ministry of Colleges and Universities. The Ministry for Seniors and Accessibility and Ministry of Colleges and Universities provide information and secretariat support to the committee as it develops its recommendations. The voting members are made up of persons with disabilities or their representatives, members of the postsecondary education sector, students and community organizations. (See Appendix A for a list of member names and roles.)

Purpose of the initial recommendations report

This document sets out the committee’s initial recommendations for proposed accessibility standards for postsecondary education. As required under the act, the report is being made available for public comment. Following the public posting period, the committee will consider all comments received and make any changes to the proposed recommendations that it considers advisable. Once finalized, the committee will submit its final recommendations for new proposed standards to the minister. As outlined by the act, the minister may adopt the recommendations in whole, in part, or with modifications.

Guiding principles

At the forefront of the committee’s work was consideration of the needs and lived experience of students with disabilities and intersecting identities. The committee embraced the mentality of “nothing about us without us” in all aspects of their work.

The following principles were foundational to the work of the committee in developing their initial recommendations:

• accessibility efforts should be proactive, rather than reactive.
• disability is a critical aspect of diversity and intersectionality. There must be a recognition of intersectionality and the compounded impact of multiple identities. Therefore the principles of equity, diversity, and inclusion underlie all aspects of the committee’s work. Barriers to accessibility and accommodation throughout a student’s academic journey, and at each stage of transition (such as, K-12 to postsecondary, undergrad to graduate, to employment), must be addressed.
• students ought to be able to navigate a system that is transparent and seamless.
• innovation should be celebrated and encouraged.
• there is a shared responsibility for accessibility across all members of an institution.

Methodology

The committee began meeting in early 2018. They spent their initial meetings discussing and identifying barriers to accessibility in the postsecondary education sector.

The committee referenced the feedback received in the 2016 accessibility survey conducted by the Ministry for Seniors and Accessibility, the Ministry of Colleges and Universities and the Ministry of Education. The committee sought additional feedback on the challenges faced by students with disabilities as a result of COVID‑19.

Throughout the committee’s tenure a range of barriers came to the forefront based on feedback from the disability community, committee members’ expertise, research, the previous legislative reviews and the Ontario Human Rights Commission. Committee members considered a wide range of barriers upon which to focus their work. As a result of many thoughtful discussions, nine main categories of barriers emerged:

1. general overarching barriers
2. attitudes, behaviours, perceptions and assumptions
3. awareness and training
4. assessment, curriculum and instruction
5. digital learning and technology
6. organizational barriers
7. social realms
8. physical and architectural barriers
9. financial barriers

The work of the committee was paused in April 2018 due to the provincial election. In March 2019, the government announced the resumption of committee work. Meetings between the ministry and the chair began in Spring/Summer 2019 and the committee resumed meeting in November 2019. The committee continued to work and meet in person through early 2020. During the pandemic, meetings took place virtually using Microsoft Teams. Based on the nine agreed upon themes, committee members were divided into corresponding small groups based on expertise and lived experience. The chair asked each small group to draft recommendations to address accessibility barriers from their assigned barrier area. The small groups met independently over the course of several months to develop their recommendations.

Small group teams then brought forward their draft recommendations to the full committee for discussion and review before final voting. In order to allow for as much meaningful discussion as possible, the majority of the committee’s votes were held electronically. The committee agreed upon a number of definitions for key terms that are used throughout this report. These terms are defined in the Glossary in Appendix B. The committee members were collaborative, engaged and dedicated throughout the experience of working together in small groups and as a full committee.

Key resources

The committee would like to acknowledge the importance of lived experience, professional experience, and consultation with relevant colleagues and stakeholders in developing their recommendations.

The committee utilized a range of resources including the following, which were of significant value:

• Accessible Campus, Council of Ontario Universities
• Assessment of Debt Load and Financial Barriers for Students with disabilities, Higher Education Quality Council of Ontario, 2011
• Disability in Higher Education: A Social Justice Approach, Evans, Nancy J., Broido, Ellen M., Brown, Kirsten, R., and Wilke, Autumn K., 2017
• Draft Framework for a Post-secondary Education Accessibility Standard, Accessibility for Ontarians with Disabilities Act Alliance, 2020
• Enhancing Accessibility in Post-secondary Education Institutions, National Educational Association of Disabled Students
• Highly Skilled Workforce Expert Panel Report, 2016
• Improving the Accessibility of Remote Higher Education: Lessons from the Pandemic and Recommendations, Higher Education Quality Council of Ontario, 2020
• Listening to Ontarians with Disabilities: Report of the Third Review of the Accessibility for Ontarians with Disabilities Act, 2005 by the Honourable David C. Onley, 2019
• Policy on Accessible Education for Students with disabilities, Ontario Human Rights Commission, 2018
• Policy Primer: Guide to Developing Human Rights Policies and Procedures, Ontario Human Rights Commission, 2013
• Policy on Ableism and Discrimination, Ontario Human Rights Commission, 2016
• Strategic Diversity Leadership, D. Williams, 2013
• Summary Report of the Disability-Related Support Review, Ministry of Training, Colleges and Universities, 2004
• Understanding Accessibility in Graduate Education for Students with Disabilities in Canada, National Educational Association of Disabled Students, 2016
• Universal Design for Learning, CAST
• We Have Something to Say Report, Provincial Advocate for Children and Youth, 2016

Education joint technical sub-committee

In order to ensure that the work of both the Kindergarten to Grade 12 and Postsecondary Education committees remained aligned, the Minister for Seniors and Accessibility welcomed both chairs to form a joint technical sub-committee representing members from both sectors and from the disability community. The Education Joint Technical Sub-Committee is made up of nine members from across both committees. The sub-committee is responsible for sharing information across the two committees and for considering areas of commonality, and in particular, considering the area of transition planning between the two sectors as a priority.

The report and initial proposed recommendations from the technical sub-committee are submitted separately from this report.

Long-term objective of the standards

To demonstrate meaningful change and provide clarity for future reviews, the committee recommends that the Postsecondary Education Accessibility Standards have a more specific long-term objective than those seen in the past. This is an aspiration to be achieved through strategic diverse leadership.

Long-term objectives have not been included in prior accessibility standards. However, the committee recommends including the following long-term objective as the statement of purpose within the Postsecondary Education Accessibility Standards so the committee’s intentions in the development of these recommendations are clear.

Recommendation 1: The long-term objective of the standards:

With the support of the Ontario government, postsecondary publicly funded colleges and universities in Ontario will implement an intentional strategy:

• that actively engages students with disabilities in the ongoing identification, removal and prevention of barriers
• that recognizes disability as a critical aspect of the education sector’s commitment to equity, diversity and inclusion that creates policies, procedures and guidelines through an intersectional accessibility lens
• where teaching and learning practices take into account the diversity of learning environments and needs throughout the academic journey

Realization of the long-term objective will result in all students with disabilities living and learning in an environment where they will:

• feel valued, welcomed and a sense of belonging
• navigate transparent systems without barriers
• be provided with opportunities to realize their full potential both inside and outside of the classroom
• have an equal opportunity to contribute, to learn and to demonstrate their knowledge

General overarching barriers

The Honourable David Onley, in his third legislative review of the Accessibility for Ontarians with Disabilities Act, 2005 in 2019, noted that Ontarians with disabilities continue to face “soul crushing barriers.” Unfortunately, these barriers are often the result of attitudes that devalue and limit the potential of persons with disabilities.

The following recommendations are intended to support the implementation and future success of the Postsecondary Education Accessibility Standards. Currently, students with disabilities are often considered as an afterthought in the development of policies and budgetary decisions, thus perpetuating the perception that students with disabilities are not valued or heard. To maximize the long-term impact of the standards, it is essential that ministries stop working in silos and work together to ensure that the spirit of collaboration and partnership is embedded across the Ontario government. Without such a collaborative environment, we risk leaving students with disabilities behind.

Recommendation 2: Proposed standards (non-regulatory)

It is recommended that the Minister for Seniors and Accessibility and Minister of Colleges and Universities co-sign and distribute a memo to all public and private colleges and universities indicating:

• the proposed standards are available for public comment
• the proactive nature of the act and the institutions’ requirements under the act
• postsecondary institutions are encouraged to implement strategies, whether or not there are standards in place, so as not to delay addressing some of the barriers that can be reduced or eliminated before a new regulation is enacted

Recommendation 3: Roll out of recommendations (non-regulatory)

The committee proposes that the Ontario government use the technical expertise of the Postsecondary Education Standards Development Committee members to clarify intent and technical accuracy during the regulatory drafting stage.

Recommendation 4: Collaboration between ministries (non-regulatory)

It is recommended that ministries with the Postsecondary Education Accessibility Standards within their mandate, cooperate, collaborate and hold each other accountable, to ensure its success.

The committee recommends that the Ontario government set up a structural and procedural arrangement to ensure broad communication and partnerships between ministries to support work related to the education sector and students with disabilities.

Recommendation 5: Future initiatives (non-regulatory)

It is recommended that future Ontario government initiatives and strategies aimed at persons with disabilities proactively consider the needs of students with disabilities and the recommendations of the Postsecondary Education Standards Development Committee. This includes programs that appear to be outside the education sector but impact the participation of students with disabilities in the education sector including the Assistive Devices Program, the Ontario Disability Support Program and attendant care services.

Recommendation 6: Postsecondary education accessibility standards plain language version

This Postsecondary Education Accessibility Standards shall in its entirety be produced in a plain language version. This plain language version of the standards shall be between 70.0 to 95.0 on the Flesch-Kincaid readability test and use easy-to-understand culturally sensitive images as required.

Timeline: Within one year of regulation being enacted

Barrier area 1: Attitudes, behaviours, perceptions, assumptions

Persons with disabilities face barriers resulting from ableism which can then assume the form of internalized ableism. That is when negative attitudes and beliefs about disability, expressed or held by others (often, people in positions of authority), are directed towards persons with disabilities, and then accepted or endorsed by them on a personal level. This results in a negative self-view including feeling "less than" and a burden, self-doubt of one’s capabilities, and, that a perception that they do not “fit” or belong. Ableism can significantly and negatively affect a person’s well-being, performance and access to opportunities in work and school.

The committee is in agreement with the Ontario Human Rights Commission’s (2018) view that “we will not have an accessible province by 2025 without tackling the social attitudes that prevent persons with disabilities from participating and contributing to the community.”

In this section, we offer specific recommendations in the following five areas, while also recognizing a multidimensional framework is required to shift culture to create lasting attitudinal and behavioural change:

• transformational leadership
• accountability: metrics and performance measures
• research and scholarship
• awareness
• language

It will be through the combination of and synergy among all the postsecondary education recommendations, the other accessibility standards and strong transformational leadership, that will help shift attitudes, behaviours, perceptions and assumptions.

Theme 1: Transformational leadership

Recommendation 7: Change management plan

All publicly funded colleges and universities shall develop a change management strategy to respond to the Accessibility for Ontarians with Disabilities Act, 2005 recommendations, and articulate this strategy to students, staff and faculty.

To consistently integrate the commitments and values of inclusion into daily practices and decision making, the institution’s change management strategy shall incorporate:

• who will lead the implementation of the Postsecondary Education Accessibility Standards
• establishing a communication plan
• how the institution intends to engage senior leaders, managers and supervisors to roll-out the plan
• how to leverage resources to effect change

Timeline: Within six months of the regulation being enacted

Recommendation 8: Communication strategy on commitment to accessibility

Senior executive leadership must develop, and adopt, an annual communication strategy that is readily accessible and understandable. The communication strategy shall:

• inform the institutional community and the public of the institution’s commitment and values related to accessibility and inclusion of persons with disabilities
• clarify the relationship between the Accessibility for Ontarians with Disabilities Act, 2005 and Ontario Human Rights Code, and the rights of students with disabilities to be accommodated in connection with programming and academic life and experiential learning under legislated requirements and the principles of the institution on equity, diversity, inclusion, accommodation and transitions
• emphasize collective responsibilities under the Accessibility for Ontarians with Disabilities Act, 2005 and the Ontario Human Rights Code
• encourage a culture of accountability
• communicate a statement of principles on accessible and inclusive pedagogy/andragogy that takes into account:
  • the diversity of learning environments within postsecondary education, including experiential learning (for example, classroom learning, labs, fieldwork, practicum placements, apprenticeships, in-person and online, etc.)
  • formal and informal learning environments
  • the diversity of learning needs within the student population, inclusive of the different ways that students, particularly students with disabilities, take in, process and communicate information
  • the diversity of academic environments and programs within colleges and universities (for example, college diplomas, university Bachelor’s, Master’s and Doctoral programs, first versus second entry programs, post graduate diplomas and certificates, etc.)
  • the diversity of teaching staff within colleges and universities (research faculty, teaching faculty, part-time and sessional faculty, instructors, etc.)
  • learning expectations, both explicit and hidden, within academic courses, programs and disciplines
  • individuality and uniqueness in teaching approaches and learning expectations in course and program syllabi, among institutions, and even among faculty within the same department at a given institution

Evidence of attainment of the Commitment to Accessibility will be provided through Annual Status Reports and the institutions Statement of Commitment will be reviewed and updated every three years.

Timeline: Within six months of the regulation being enacted

Recommendation 9: Infrastructure and resources (non-regulatory)

To support the success of the Postsecondary Education Accessibility Standards, the Ontario government, as well as Colleges and Universities shall demonstrate their commitment to accessibility and disability inclusion through their actions.

New Postsecondary Education Accessibility Standards come with additional responsibility for an already overburdened system. It is recommended the Ministry of Colleges and Universities and postsecondary institutions allocate sufficient resources and build infrastructure across the institutions and ministries to implement the standards and change management plan. Providing adequate resources demonstrates a significant commitment to address the barriers in the education system faced by students with disabilities.

The intended uses for increased resources include but are not limited to:

• supporting the change management plan. Increasing funding and support to staff responsible for the act to support the change management plan
• increasing support to the services for students with disabilities: make use of federal funding and increase the existing Accessibility Fund for Students with Disabilities to enhance services and supports available for students with disabilities at postsecondary institutions (Council of Ontario Universities, 2020) as defined by the Accessibility Fund for Students with Disabilities eligibility requirements
• supporting universal design and online learning infrastructure: ensure postsecondary institutions have the resources and infrastructure to engage students and that all students have an equal opportunity to succeed (Council of Ontario Universities, 2020)
  • a recent example of this is Ontario’s Virtual Learning Strategy, launched in 2020
• securing services for multimedia accessibility (for example, closed captioning and described video)
• training disability-specialized career centre staff and expand programming to support student transition to employment
• capacity building activities in consideration of funding these activities per collective agreements and to address resistance and attitudinal barriers

Recommendation 10: Leveraging funding (non-regulatory)

It is recommended that postsecondary institutions’ senior executive leadership identify fundraising efforts targeted to support disability-related initiatives, especially initiatives that support the objectives of the Postsecondary Education Accessibility Standards and combating ableism.

Such initiatives may include scholarships for low income students with disabilities, innovative programs for students with disabilities, research and scholarship in the field of disability, etc.

Recommendation 11: Traditions, myths, symbols (non-regulatory)

Colleges and Universities are encouraged to ensure a consistency in their efforts on a symbolic level to demonstrate that accessibility and inclusion are priorities.

This includes, but is not limited to:

• recognition and celebration of efforts that support equity-deserving groups and align with the institutions’ equity, diversity and inclusion commitment. This can be through outlets such as award ceremonies
• letter of support from senior executive leaders for accessibility efforts to keep the objective of these standards at the forefront and demonstrate ongoing efforts to shift attitudes and behaviours
• an annual memo from senior executive leaders celebrating occasions such as the International Day of Persons with Disabilities and National AccessAbility Week

Theme 2: Accountability: Metrics and performance measures

Recommendation 12: Annual status report

Every publicly funded university and college should review, update and maintain the Annual Status Report on the progress of actions taken related to the regulatory and non-regulatory recommendations in the Postsecondary Education Accessibility Standards, including Quality Assurance-related metrics and innovative practices as they become available.

Timeline: Within one year of the regulation being enacted

Recommendation 13: Improving campus climate related to accessibility

1. The Ontario government shall develop or update an existing accessible standardized campus climate instrument to be administered to all enrolled students and current employees at postsecondary institutions to measure the effectiveness of efforts to address ableism amongst the students, and employees to identify gaps in initiatives to shift attitudes, behaviours, beliefs and assumptions related to disability.
   
   The instrument shall assess a wide range of accessibility-related issues including, but not limited to:
   • satisfaction of students with disabilities about accessibility and accommodations (on campus and experiential learning)
   • satisfaction of students with disabilities with campus life and engagement
   • the experiences of students with ableism, external and internal, and their sense of belonging
   • faculty/instructor/administration awareness of and attitudes towards students with disabilities, accessibility and accommodations
   • inclusive teaching practices
   • awareness and attitudes of non-disabled students towards their peers with disabilities, accessibility and accommodation
2. Each postsecondary institution shall develop a plan to administer the instrument, to manage the analysis, and to respond to the feedback. Each postsecondary institution shall notify the prospective survey participants about the accessible formats and communications supports available to aid completing the campus climate instrument. Additionally, the plan must:
   • consider, where possible, embedding relevant accessibility or disability questions within existing surveys (for example, employees Education, Diversity and Inclusion surveys, student feedback surveys, etc.) to reduce survey fatigue
3. Make publicly available in the Annual Status Report the aggregate results within six months of administering the climate instrument.
4. Specify the actions the institution will take to address the findings of the campus climate instrument questions including creating a committee to analyze and respond to the survey responses. Each postsecondary institution’s Annual Status Report shall include the progress of measures taken to address these findings.
5. Each postsecondary institution shall administer the standardized campus climate instrument every three years.

Timeline: a) Published within 18 months of the regulation being enacted, b) within two years of the regulation being enacted, c) within six months of administering the survey, d) within 30 months of the regulation being enacted, e) within three years of the previous survey being administered

Recommendation 14: Establish a committee

Each institution shall establish or entrust a new or existing committee with the responsibility of addressing their community’s disability-related attitudes, behaviours, perceptions, assumptions, physical barriers, etc. This committee will analyze the findings of the campus climate instrument and advise how best to respond to the feedback while also complying with the postsecondary education regulations. The committee chair should have content knowledge in the area of disability and intersectionality.

Postsecondary institutions shall ensure that student members of this committee are fairly compensated and are engaged throughout the entire planning and design process for any physical spaces, and in any plans, procedures or policies developed as part of these standards.

The committee shall meet a minimum of twice annually and report to a senior executive leader (for example, vice president of human resources and/or vice provost, students). The input of this committee, including the responses to their input, shall be included in all project updates and the final accessibility report/review.

The majority of the members of the committee must be students and employees with diverse lived experiences of disability and with consideration of intersectional identities, and include but not be limited to:

• representative(s) from the Office(s) for Students with Disabilities
• representative of an Accessibility for Ontarians with Disabilities Act, 2005 lead for the institution, if applicable
• representative of the HR department managing staff/faculty accommodations
• representative(s) of other Human Rights Offices, if applicable, established at the institution (for example, race relations, Indigenous, sexual diversity office, etc.)
• representative(s) from Facilities Services for the institution to address physical barriers
• other representatives of persons with, and without, disabilities as designated by the institution to ensure a range of perspectives

Timeline: Within 30 months of the regulation being enacted

Recommendation 15: Representation data collection

The Ministry for Seniors and Accessibility, in collaboration with partner ministries and stakeholders, shall create a standardized mechanism for postsecondary institutions to collect data about students with disabilities and persons with disabilities they employ, including tracking most common institutional barriers and human rights complaints.

All postsecondary institutions shall collect, analyze and report this data in the Annual Status Report. The institutions shall:

• clearly set out a purpose of data collection that is consistent with the Ontario Human Rights Code
• advise the people about whom data are being collected, as well as the broader public in general: why such information is being gathered, its potential uses, how the data will be collected, and the steps taken or, that will be taken, to protect privacy and confidentiality of responses
• collect aggregate data that must not include any information that would reveal the identity of persons with disabilities
• take measures to respond to trends and address inequalities that may arise from data collection (for example, underrepresentation of people with certain types of disabilities), recognizing representation does not measure inclusion
• ensure data collection procedures, storage, access and disclosure are carefully controlled. Always respect confidentiality and dignity

Data collected must include, but are not limited to:

• number of students with disabilities registered with the offices for students with disabilities
• the nature of the primary disability (for example, physical, developmental/intellectual, mental health, etc.), nature of secondary disabilities, and be disaggregated to determine whether the student identifies with any other code ground (for example, sex, race, Indigenous ancestry, etc.)
• proportion of first-entry undergraduate, and graduate students, who self-identify as a student with a disability and the proportion of these students who identify themselves as holding other identities (for example, LGBTQ, Black, etc.)
• number of students with disabilities participating in academic pathway programs, if applicable
• number of non-teaching employees who self-identify as a person with a disability
• number of faculty/instructors who self-identify as a person with a disability

Timeline: Within 18 months of the regulation being enacted

Recommendation 16: Metrics and performance measures

To assess the institutions’ performance, and prevent or ameliorate disadvantage, measures of retention, graduation rate and time to completion will include collecting data on full-time and part-time students with disabilities.

The institutions will analyze the retention, graduation and time to completion rates and shall determine if specific interventions to improve retention and graduation rates are required. This may include assessing if barriers, including attitudinal barriers, impact these rates. If specific action is taken, this shall be reported in the Multi-Year Accessibility Plan.

Where other data are collected to assess the institutions’ performance, postsecondary institutions will identify strategies to ensure part-time students with disabilities are not excluded from data analysis.

Timeline: Within two years of the regulation being enacted

Theme 3: Research and scholarship

Recommendation 17: Research and scholarship (non-regulatory)

It is recommended that the Ministry of Colleges and Universities and publicly funded colleges and universities:

• embed accessible and inclusive pedagogy/andragogy as a criterion for evaluation into institutional teaching awards
• embed accessible pedagogy/andragogy as a criterion for evaluation into provincial and institutional research grants and funding opportunities
• stimulate funding for research and scholarship in the area of disability
• incentivize research and scholarship in the area of disability including embedding accessible pedagogy/andragogy as a criterion for evaluation into provincial and institutional research grants and funding opportunities and into institutional teaching awards
• create scholarships for undergraduate and graduate students who are enrolled in disability studies to support research and scholarship in this area
• encourage inter-disciplinary collaborations to advance disability knowledge in higher education

Theme 4: Awareness

Recommendation 18: Awareness

The Ontario government shall take an active role in the promotion of a cultural shift towards an accessible and inclusive society.

The government will develop guidance documents for obligated organizations and conduct a sustained, multi-faceted ongoing public education campaign on accessibility. Any guidance materials developed should support the Ontario Human Rights Commission’s Policy on Accessible Education for Students with Disabilities, Policy on Ableism and Discrimination Based on Disability, and be made in collaboration with members of the disability community.

Timeline: Within 18 months of the regulation being enacted

Theme 5: Language

Recommendation 19: Language

The ministry shall adopt new definitions provided in the glossary of terms (Appendix B), in the new Postsecondary Education Accessibility Standards.

Timeline: To be included in the regulation before enactment

Barrier area 2: Awareness and training

Accessibility and inclusion are constantly evolving, and knowledge that may be current one year is likely to be outdated the next. Recommendations in this section build upon the requirements of the information and communications standards. However, there is currently no requirement for periodic refreshing of any previously received staff training.

Our recommendations are meant to cascade and be viewed as a whole. We present an overarching recommendation for strong leadership by the Ontario government in coordinating the development of the nine training recommendations for specific audiences.

To ensure a consistent and portable quality of training for all postsecondary employees and students, the Ministry for Seniors and Accessibility should take the lead in developing, renewing and providing standardized accessibility training across the province regardless of postsecondary institution.

All employees (faculty and teaching staff, as well as, academic, student services and support staff) should receive foundational employee onboarding training and awareness education related to the act and how it applies to a postsecondary education setting, ableism and discrimination, as well as, engage in activities to promote self-examination. As with other mandatory training for staff, accessibility training should be renewed on a regular basis.

Theme 1: Government leadership

Recommendation 20: Accessibility lens training

Individuals responsible for developing and/or delivering institutionally sanctioned programming must be trained on applying the accessibility lens (recommendation 99) in all programming. This include student groups, student unions and societies.

Timeline: Within two years of regulation being enacted

Recommendation 21: Training

The Ministry for Seniors and Accessibility will engage persons with disabilities to co-develop standardized training for employees on their rights and responsibilities under the Ontario Human Rights Code, Postsecondary Education Accessibility Standards and all other accessibility standards as they apply to postsecondary institutions. Online and in-person components shall be provided at no cost to postsecondary institutions across the province. All postsecondary institution employees shall undergo this training as soon as practicable after they are assigned their applicable duties.

Timeline: To be developed within one year of regulation being enacted. Training to be implemented within one year after development

Recommendation 22: All employees

All postsecondary institution employees shall undergo mandatory employee training at on-boarding and be renewed every three years. This training will be a combination of on-line and in-person components that will educate employees on their rights and responsibilities under the Ontario Human Rights Code, the Postsecondary Education Accessibility Standards and all other accessibility standards as they apply to postsecondary institutions, and on ableism, microaggressions and discrimination.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Theme 2: Training for specific audiences

Recommendation 23: Educators

In addition to recommendation 22, all postsecondary educators shall undergo mandatory educator training related to:

• Integrated Accessibility Standards Regulation with an emphasis on their responsibility in procurement and purchase of accessible equipment and accessible course content materials
• the accommodation process as outlined by the Ontario Human Rights Commission
• the Marrakesh VIP Treaty (formally the Marrakesh Treaty to Facilitate Access to Published Works by Visually Impaired Persons and Persons with Print Disabilities)
  • the Ontario government shall develop the mandatory training resources on the Marrakesh Treaty
• the impact choosing textbooks late has on students with disabilities
• the minimum accessible and inclusive pedagogy/andragogy standards per Assessment Curriculum and Instruction Barrier recommendations 31 and 32 related to accessibility standards for teaching and learning. This also supports the Digital learning and technology recommendation 78 and the Organizational barrier recommendation 107

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 24: Postsecondary Education administrators and leadership

In addition to recommendation 22, all postsecondary education administrators and senior leadership shall undergo mandatory training related to:

• system-level barriers to accessibility and the impacts of policy decisions
• organizational responsibility for preventing and addressing human rights issues including organizational liability for the actions of employees (for example, faculty refusing academic accommodations or purchasing inaccessible educational technology)
• developing, preventing and removing barriers with an accessibility lens
• staffing decisions (for example, late hiring and sessional staff) and their impact on students with disabilities
• the impacts of lack of funding for additional accessibility training on the overall experience of students with disabilities
• the importance of allyship

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 25: Disability services staff

In addition to recommendation 22, all postsecondary education Disability Services staff shall undergo:

• deeper understanding of ableism, microaggressions and discrimination
• social aspects of disability and unique barriers students with disabilities experience in the postsecondary education environment
• allyship
• transition for students with disabilities

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 26: Career counsellors/advisors

In addition to recommendation 22, all postsecondary education career counsellors/advisors, co-op officers, shall undergo mandatory career counselling training related to:

• employment standards under the Integrated Accessibility Standards Regulation
• specialized training on career transitions for persons with disabilities and counselling students with disabilities on career options
• how intersectionality may further compound the challenges students with disabilities may have in employment

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 27: Media/creative arts staff

In addition to recommendation 22, all postsecondary education Media/Creative Arts staff shall undergo mandatory media and creative arts training related to:

• creating and assessing accessible media and responsibilities under the information and communications standards
• media portrayal of people with disabilities
• using inclusive language

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 28: Information technology/communications

In addition to recommendation 22, all postsecondary education Information Technology (IT)/Communications staff shall undergo mandatory IT/communications training related to:

• creating and assessing accessible media and responsibilities under the information and communications standards
• digital/accessible learning technologies
• using inclusive language

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 29: Facilities Management/Design/Construction staff

In addition to recommendation 22, all postsecondary education Facilities Management staff shall undergo mandatory architecture and design training related to:

• physical and architectural barrier recommendations 127-129
• the training will align with the recommendations developed under the physical and architectural barrier area, including recommendation 150, any professional working with the institution by the vendor for which they are working at the time of bidding for a project shall provide proof of training

Employee training must be renewed every three years.

Timeline: Within one year of ministry making training available to postsecondary institutions (recommendation 21)

Recommendation 30: Event planners and hosts

1. The ministry, in collaboration with postsecondary institutions, shall consult with stakeholders to create and/or adopt an accessible event planning tool.
2. Postsecondary institutions shall publish and require the use of the accessible event planning tool indicated when delivering in-person and virtual events and activities to ensure they are accessible to students with disabilities.
3. All postsecondary education staff responsible for event planning shall undergo mandatory event management training that includes in-person and on-line components on their rights and responsibilities under the Ontario Human Rights Code, Postsecondary Education Accessibility Standards and all other accessibility standards as they apply to postsecondary institutions. Individuals who are responsible for or highly involved/integral to the planning and hosting of events shall complete the training. These individuals include, but are not limited to:
   1. student affairs personnel
   2. student government, student societies/associations and student groups
   3. orientation leaders
   4. sports and recreation staff and volunteers
   5. residence administration and staff, including residence life personnel
   6. personnel responsible for planning large-scale institutional events such as convocation

Training shall include how to create accessible media and other responsibilities pertaining to planning or hosting events as required by the information and communications standards and must be renewed every three years.

Timeline: The accessible event planning tool to be adopted within one year of regulation being enacted. Training in the use of the accessible event planning tool to be administered within one year of the postsecondary institutions adopting the tool.

Barrier area 3: Assessment, curriculum and instruction

Postsecondary institutions have grappled with providing equitable access to assessments, curriculum and instruction for students with disabilities. This struggle arose because the current pedagogical practices in higher education evolved from a system that did not consider the full inclusion of students with a diverse range of abilities and learning needs. As a result, students with disabilities have come to rely on a cumbersome and expensive process of vetting and approving academic accommodations so that they may gain equal access to postsecondary education.

We approached the barriers in our learning environments with a systemic lens – that the system was not designed for inclusion, and in order to change this, we need to look at all the overall systems that impact and support learning in postsecondary education.

Our recommendations fall into the following six key areas:

• pedagogy/andragogy
• accessible format educational materials
• institutional responsibility
• quality assurance
• diversity of learning environments
• proposals

Theme 1: Pedagogy/andragogy

Recommendation 31: Accessibility standards for teaching and learning

The Ontario government shall work with postsecondary institutions, especially with their centres for teaching and learning, to create a common set of minimum accessibility standards for teaching and learning. The set shall include best practices for teaching in a variety of settings, including but not limited to in-person and virtual:

• lecture
• seminar
• labs
• studios
• field placements
• clinical placements

The minimum standards and expectations should be created from the best research, reports and practices, including but not limited to:

• Universal Design for Learning
• Accessiblecampus.ca

Timeline: Within two years of the regulation being enacted and to be reviewed every five years

Recommendation 32: Inclusion of standards on accessible and inclusive pedagogy/andragogy in the quality assurance process

1. Postsecondary institutions should implement the standards and guidelines in Recommendation 31 to embed accessible and inclusive pedagogy/andragogy requirements within their quality assurance processes. Postsecondary institutions should collaborate with Ontario Universities Council on Quality Assurance and the Ontario College Quality Assurance Service to meet this recommendation.
2. Non-Regulatory best practices to be shared across postsecondary education sector.

Timeline: a) To be developed within one year of the regulation being enacted and reviewed and updated within one year of Recommendation 31 coming into effect

Recommendation 33: Employable skills for students with disabilities in alternate pathway programs

Require postsecondary institutions, in collaboration with industry experts and the disability community, to ensure that students with disabilities in alternative pathway programs obtain a portfolio of employability skills prior to completion, where appropriate.

Timeline: Within 18 months of the regulation being enacted

Theme 2: Accessible format educational materials

Recommendation 34: Accessibility of textbooks and reading packages

Postsecondary institutions shall mandate the use of textbooks and reading packages which are available in multiple formats (hard copy, electronic copy, audio, etc.), in compliance with the Marrakesh Treaty.

Furthermore, postsecondary institutions shall require that accessible format textbooks and reading packages be available within three weeks of acquisition of materials for the class at large. Postsecondary institutions shall ensure that materials published within the past decade are compliant, and older materials are made compliant on request.

Timeline: To be developed within one year of the regulation being enacted and reviewed

Recommendation 35: Accessibility of course materials and assessments

All course materials and assessments created by faculty and members of teaching teams shall be produced in an accessible format that can be converted to meet different accessibility needs.

Where accessible formats are not available, course materials and assessments sourced by faculty and members of teaching teams, alternative means of representing the information content which permit students with disabilities to access the learning and equal opportunity to achieve the relevant essential requirements, shall be provided.

Timeline: Within one year of the regulation being enacted

Recommendation 36: Accessibility of multimedia course materials and assessments

All multimedia course materials and assessments created and sourced by faculty and members of teaching teams shall be produced and available in multiple accessible formats.

Where accessible formats are not available for multimedia course materials and assessments sourced by faculty and members of teaching teams, alternative means of representing the information content which permit students with disabilities to access the learning and equal opportunity to achieve the relevant essential requirements, shall be provided.

Timeline: Within one year of the regulation being enacted

Recommendation 37: Training about accessible document and multimedia formats (non-regulatory)

The Ontario government shall develop the mandatory training resources on accessible documents and multimedia resources for recommendation 22.

Recommendation 38: Resources (non-regulatory)

In consideration of the costs involved in hiring subject matter experts in accessible and inclusive pedagogy/andragogy, and creating accessible materials, the Ontario government should provide dedicated funding to the universities and colleges to support these standards.

Recommendation 39: Access to instructional information (non-regulatory)

Teaching staff shall ensure that the verbal contents of their presentations, labs, studios and lectures (for example, PowerPoints) can be captured by students in formats appropriate to their accessibility needs. Where necessary, this includes the timely publication of printed and digital course materials.

Theme 3: Institutional responsibility

Recommendation 40: Linking assessments to essential academic requirements

Where this is not already in practice, postsecondary institutions shall ensure that programs and courses explicitly identify how each assessment connects to the essential academic requirements, taking into consideration the method of course delivery (in person, remote, online, blended).

Timeline: Beginning one year after the regulation has been enacted, and no later than one quality assurance cycle after this point

Recommendation 41: Resource guides on accessible and inclusive pedagogy/andragogy

The Ministry of Colleges and Universities, working with Colleges Ontario, the Council of Ontario Universities and postsecondary institutions, shall create and make available resource guides on accessible and inclusive pedagogy/andragogy. These resource guides shall be shared with all teaching staff, including but not limited to, full-time, part-time and sessional faculty, lab demonstrators, teaching assistants and guest presenters involved in their courses. Where possible, resource guides should be tailored to broad discipline areas, particularly those with more significant technical considerations (such as science, technology, engineering and mathematics healthcare, the arts). These resource guides should be refreshed regularly (for example, once every five years), and should be independent of method of course delivery (in-person, blended, remote, online, etc.). These resource guides should be developed using the statement of principles on accessible and inclusive pedagogy/andragogy.

Timeline: Within three years of the regulation being enacted

Recommendation 42: Guidance on synchronous and asynchronous learning (non-regulatory)

The Ministry of Colleges and Universities, working with Colleges Ontario and the Council of Ontario Universities, should develop a series of best practices and guidance documents on creating and accommodating accessible and inclusive synchronous online and asynchronous online course content delivery. These guides should be made for faculty, instructors and course designers to use in their teaching practice.

Recommendation 43: Expert resources on accessible and inclusive pedagogy/andragogy (non-regulatory)

Postsecondary institutions should create staff roles for dedicated experts on accessible and inclusive pedagogy/andragogy to act as a resource for course coordinators, part-time and sessional faculty, lab demonstrators, teaching assistants and guest presenters involved in their courses. Where possible, discipline-specific expertise should be cultivated within each institution.

Theme 4: Quality Assurance

Recommendation 44: Adherence to accessible and inclusive pedagogy/andragogy standards

Postsecondary institutions shall report on their adherence to accessible and inclusive pedagogy/andragogy guidelines/standards through their quality assurance processes, for both newly developed programs and courses, and when reviewing existing programs and courses.

Timeline: Beginning one year after the regulation has been enacted, and no later than one quality assurance cycle after this point

Recommendation 45: Identification and communication of bona fide and essential academic requirements

Essential academic requirements of a program/course need to be explicit and available to all stakeholders. To parallel the Kindergarten to Grade 12 (K-12) system and to comply with the Ontario Human Rights Commission recommendation (8.4.5 – bona fide academic requirements, Accessible Education for Students with Disabilities), postsecondary institutions must identify bona fide essential academic requirements for all programs and courses and make them publicly available. This can be accomplished through the quality assurance process and posted in multiple locations such as the program website, program manual and course outlines/syllabus.

Timeline: Beginning one year after the regulation has been enacted, and no later than one quality assurance cycle after this point

Recommendation 46: Reporting of accessibility of course materials

Use of accessible format course materials shall be evaluated and documented by departments/faculties as part of the quality assurance process.

Timeline: Beginning one year after the regulation has been enacted, and no later than one quality assurance cycle after this point

Recommendation 47: Accessibility embedded into the quality assurance process (non-regulatory)

The Ministry of Colleges and Universities should work with Ontario Universities Council on Quality Assurance and the Ontario College Quality Assurance Service to include minimum accessibility standards and guidelines (recommendations 31, 44 and 45) into the program review and approval process.

Recommendation 48: Documenting accessibility in student course feedback surveys

Postsecondary education student course feedback surveys and program reviews shall include mandatory question(s) related to the Postsecondary Education Accessibility Standards compliance and inclusive instructional design (such as, integrate lived experiences of students with disabilities, including those with intersectional identities, and backgrounds, of both students and teaching team) in the learning environment. The responses to these questions shall be made available to the faculty member’s direct supervisor and data collected will be reported as part of the Quality Assurance Review.

Timeline: Beginning one year after the regulation has been enacted, and no later than one quality assurance cycle after this point

Theme 5: Diversity of learning environments

Recommendation 49: Specialized discipline hubs (Science, Technology, Engineering and Mathematics, trades, healthcare and the arts) (non-regulatory)

Postsecondary institutions shall create internal discipline-specific expertise “hubs” in developing accessible and inclusive pedagogy and andragogy approaches in these fields. These “hubs” shall be formed by identifying faculty and teaching staff in Science, Technology, Engineering and Mathematics (STEM), trades, healthcare and arts disciplines to work with centralized institutional resources (see recommendations 39 and 41) and, where appropriate, external subject matter experts.

Recommendation 50: Virtual and in-person labs and simulations (non-regulatory)

Postsecondary institutions shall facilitate regular reviews of existing and new lab- and practical space-oriented instruction, including in the context of Science, Technology, Engineering and Mathematics (STEM), healthcare and arts programs, as part of the quality assurance process. These reviews will focus on the essential academic requirements of the labs and practical activities, in order to ensure that students with disabilities have equal opportunity to participate in this aspect of their programs effectively. Reviews shall take place through the quality assurance process for courses and programs.

Postsecondary institutions shall ensure that all in-person and virtual labs and practical activities are delivered in accessible ways that allow for equal opportunity for student engagement, with audio description, captioning and sign language interpretation as appropriate.

When sourcing simulation activities to complement or supplement in-person and virtual labs, postsecondary institutions shall provide support to teaching teams to ensure the accessibility of the simulation activities.

Recommendation 51: Symposia, seminars, colloquia and conferences

Postsecondary institutions shall mandate that all seminars, symposia, colloquia and conferences that are part of the formal and informal learning requirements of programs of study adhere to accessible and inclusive event planning and content delivery guidelines. (Applicable both to in person and virtual events.)

Timeline: Within one year of the regulation being enacted

Recommendation 52: Graduate supervision

1. Ministry of Colleges and Universities, working with the Council of Ontario Universities, shall develop a common set of guidelines and resources for graduate faculty members in accessible and inclusive supervision of graduate students with disabilities, including best practices for virtual supervision.
2. Postsecondary institutions shall mandate that all faculties of graduate studies and graduate departments have explicit policies, practices and guidelines on accessibility and accommodation for graduate students with disabilities, which are developed in a consultative manner. Policies should include consideration of disclosure, accommodation, student supervision and graduate assessments (for example, comprehensive exams and thesis defenses), and take into account the roles of graduate students as academic/research staff and university employees.
3. Review of these policies shall be attached to the graduate program quality assurance process.

Timeline:

1. Within one year of the regulation being enacted
2. Within three years of the regulation being enacted
3. Beginning one year after ‘Part b’ has been enacted, and no later than one quality assurance cycle after this point

Recommendation 53: Admission and employment offer letter practices for graduate students

Postsecondary institutions shall review admissions and employment offer letter practices for graduate programs and academic employment opportunities, to ensure that they are clearly separated, with appropriate accessibility and accommodation language that directs students to the relevant offices for each aspect of their graduate student experience.

Timeline: Within two years of the regulation being enacted

Recommendation 54: Student employee accommodations

Postsecondary institutions shall ensure that student employees are included in all employee policies related to provision of workplace accommodations and that these policies and procedures are clearly communicated and accessible to all stakeholders. Accommodations for students to meet the expectations of their employment will be provided through the employee accommodation policies and procedures in keeping with the employment standards and guidelines set out by the Ontario Human Rights Commission on accommodating persons with disabilities.

Timeline: Within one year of regulation being enacted

Recommendation 55: Professional practicum placement supervision

1. Postsecondary institutions, working with appropriate stakeholders including students with disabilities, shall develop a common set of guidelines and resources for practicum placement preceptors in accessible and inclusive supervision of students with disabilities, including virtual supervision best practices.
2. Review of these guidelines shall be attached to the program quality assurance process.

Timeline:

1. Within one year of the regulation being enacted
2. Beginning one year after ‘Part a’ has been enacted, and no later than one quality assurance cycle after this point

Recommendation 56: Tracking of accessibility supports in the work integrated learning setting

Postsecondary institutions shall create and maintain a record of accessibility features and supports available for students with disabilities at placement settings prior to finalizing agreements for work integrated learning placement opportunities in a consultative manner.

Timeline: Within one year of the regulation being enacted

Recommendation 57: Jurisdiction of accessibility supports in work integrated learning settings (non-regulatory)

Ministry for Seniors and Accessibility should provide guidance to postsecondary institutions and employers with respect to the division of responsibilities and applicability of the act’s standards and accommodations (Ontario Human Rights Commission) for students with disabilities in required work integrated learning settings.

Theme 6: Proposals

Recommendation 58: Competencies and professional societies (non-regulatory)

The Ministry of Colleges and Universities should take a leadership role in ensuring accessibility for students and new professionals with disabilities by advocating for accessibility standards to their competencies (which become bona fide academic requirements in postsecondary education) to be created and adopted by accreditation and professional bodies (for example, Ontario College of Physicians and Surgeons), both provincial and national.

Recommendation 59: Communities of practice (non-regulatory)

Ministry of Colleges and Universities should work with discipline-specific professional societies to encourage the establishment of communities of practice whereby accessible format materials and specialized accessibility solutions to student needs (particularly those involving mainstream and assistive technology deployed in new ways) can be shared between and amongst institutions and faculty members in a proactive manner. Over time, this will result in the creation of a province-wide series of discipline-specific resource hubs for accessible format materials and academic accommodations.

Recommendation 60: Accessible technology (non-regulatory)

In alignment with Phase 2 of the Information and Communications recommendations and the proposed “accessibility ecosystem” model, the Ministry of Colleges and Universities should work with postsecondary institutions on relationship building with technology vendors to work towards accessibility in new innovative technologies and platforms that can impact education in the next decade.

Recommendation 61: Resource library (non-regulatory)

Postsecondary institutions, in collaboration with the Ministry of Colleges and Universities, should create a centralized repository of accessible and inclusive course content, including, but not limited to, print matter, textbooks and accessible multimedia resources, potentially housed through the institutions’ libraries. Via such a repository, faculty and teaching team members can share (upload or download) accessible course content.

Recommendation 62: Braille, captioning, described video and sign language interpretation

1. The Ontario government should explore, in partnership with postsecondary institutions, employers and apprenticeship bodies, establishing a postsecondary course to train live captionists, possibly in partnership with a court stenographer’s course.
2. The Ontario government should explore, in partnership with postsecondary institutions, employers and apprenticeship bodies, increasing capacity in the province’s training capacity for American Sign Language (ASL) interpreters, with an emphasis on technical American Sign Language (particularly for science, technology, engineering and mathematics, trades and healthcare fields).
3. The Ontario government should explore, in partnership with postsecondary institutions, employers and service providers, increasing capacity in Braille production for educational materials in the province.
4. The Ontario government should explore, in partnership with postsecondary institutions, employers and service providers, increasing capacity in described video production for educational materials in the province.
5. The Ontario government shall create tools, resources and guidelines for the use and increased availability of Described and Integrated Described Video.

Timeline: Within one year of the regulation being enacted

Recommendation 63: Standards applying to teaching team and student-facing staff (non-regulatory)

The Ontario government should ensure that the Postsecondary Education Accessibility Standards apply effectively to accessibility barriers experienced by administrators, faculty, adjunct faculty and teaching staff in the context of postsecondary education.

Barrier area 4: Digital learning and technology

In an accessible digital learning environment, students with disabilities must be able to independently and effectively access and use technology, produce and consume content, and engage in learning. The context of the recommendations in this section span the postsecondary digital learning environment, where learning takes place online, remotely or blended using digital technology and digital content.

These recommendations were developed by committee members with expertise in digital technology, pedagogy, content, policy, procurement and practice. Each requirement involves barriers experienced or witnessed by one or more members.

Our recommendations fall into the following six key areas:

• accessible technology
• accessibility plan
• accessible procurement support
• accessibility training/practice
• accessible and inclusive pedagogy/andragogy
• accessible content

Theme 1: Accessible technology

Recommendation 64: Accessible and usable technology

Technology used in digital learning must be accessible to, and usable by, students with disabilities and be compatible for use with common assistive technologies and devices to accommodate a wide range of disability-related needs.

Timeline: Within six months of regulation being enacted

Recommendation 65: Accessible technology definitions

The Ministry of Colleges and Universities to provide and adopt clear and consistent definitions across the education sector for key terms relating to digital learning and technology.

Timeline: Within six months regulation being enacted

Recommendation 66: Accessible technology alternative

In cases where technological accessibility barriers continue to exist, a functionally usable alternative option meeting the requirements of the course and agreed upon by both the student and the educator must be provided for each barrier with an explanation prior to the start of the course or as soon as reasonably possible.

Timeline: Within six months of regulation being enacted

Recommendation 67: Accessible technology alternative documentation and review

All instances of functionally usable alternative options will be documented and reviewed by the postsecondary institutions each term to determine if a more suitable permanent solution has been identified, in the case of any of the following:

• if the student is still registered in the course, by the student and educator
• where the student is no longer taking the course, by the institutional lead for accessibility in consultation with the educator

Timeline: Within six months of regulation being enacted

Theme 2: Accessibility plan

Recommendation 68: Digital learning and technology plan

Each postsecondary institution must develop and make publicly available a plan to seamlessly include accessibility in the digital learning and technology used throughout the academic journey of all students with disabilities.

Timeline: Within six months of regulation being enacted

Recommendation 69: Digital learning and technology plan consultation

The Digital Learning and Technology plan must be created in consultation with a diverse body of stakeholders that includes students with disabilities.

Timeline: Within six months of regulation being enacted

Recommendation 70: Equitable access to digital technology

Regardless of the stage in the learning process, equitable access to resources, opportunities and services should be made available to students with disabilities at no additional cost to the student.

Timeline: Within six months of regulation being enacted

Recommendation 71: Identify and communicate digital learning and technology intentions

Postsecondary institutions and educators are required to identify in advance, and to communicate to students, the accessibility features of the digital technology and learning components needed to meet the essential requirements of each course.

Course syllabi, where known in advance, will indicate which technology will be used in the courses. Where new technology is introduced after the start of class, class input will be sought, and feedback related to accessibility will be addressed as a priority.

Timeline: Within six months of regulation being enacted

Recommendation 72: Accessibility of the technology

Postsecondary institutions shall include in their Digital Learning and Technology plan a way to provide, communicate and reinforce with educators a mechanism to vet the accessibility of the technology and content used.

Timeline: Within six months of regulation being enacted

Recommendation 73: Removal of digital learning and technology barriers

Postsecondary institutions shall plan for the identification of, and removal of, systemic and environmental barriers that hinder a student’s digital learning.

Timeline: Within six months of regulation being enacted

Recommendation 74: Accessible communication process

Postsecondary institutions shall ensure the availability of accessible communication processes for collaboration: student-to-student, student-to-educator, and student-to-internal and external partners.

Timeline: Within six months of regulation being enacted

Recommendation 75: Digital inclusion in multi-year plan

Postsecondary institutions shall report in their multi-year accessibility plan and the annual status reports, how they have implemented their commitment of disability inclusion for all stages of the academic journey, including addressing any inequities to digital learning.

Timeline: Within six months of regulation being enacted

Theme 3: Accessible procurement support (non-regulatory)

Recommendation 76: Accessible digital technology lead (non-regulatory)

1. Postsecondary institutions should appoint at least one high-level, institutional employee as the “accessible digital technology lead,” to support faculty/educators in the procurement/acquisition of digital technologies for learning, content creation and training.
   • If a separate “accessible digital technology lead” is not possible, then the accessibility lead for the institution must take on this role, which may involve additional training.
2. The accessible digital technology lead should have demonstrated knowledge or qualifications in accessible technology core requirements to ensure purchases have the highest degree of conformance with accessibility standards.
3. It shall be the responsibility of the accessible digital technology lead to incorporate accessibility design criteria and features when procuring or buying goods, services or facilities, for example as included in the US Voluntary Product Accessibility Template (according to the Section 508 Regulations).

Recommendation 77: Accessible digital technology lead reporting (non-regulatory)

The digital technology accessibility plan should report on the activities and accomplishments of the accessible digital technology lead in the annual status report.

Theme 4: Accessibility training/practice

Recommendation 78: Time to practice and learn digital learning and technology accessibility features

Students must be given the time to learn and practice the accessibility features of digital technologies before having to use them in learning.

Timeline: Within six months of regulation being enacted

Recommendation 79: Mitigation of technology barriers

To ensure effective mitigation of technology barriers, students with disabilities shall be offered an accessible feedback, tracking and reporting mechanism along with the contact information of the Ministry for Seniors and Accessibility compliance support services and technical services in the institution. The accessible digital technology lead shall include information from this feedback process in assessing the accessibility of the technologies procured/acquired. Systematic feedback shall also be obtained periodically from a representative sample of students with disabilities.

Timeline: Within six months of regulation being enacted

Recommendation 80: Assessment methods

Instructors shall include details of tools proposed to be used for assessment in the course syllabus. When not known in advance, students with disabilities must be given an opportunity to learn and practice any new digital technologies in a mutually agreed upon time frame, which considers the circumstances of the requester, and the urgency of the request, before using them in any assessments.

Timeline: Within six months of regulation being enacted

Theme 5: Accessibility and inclusive pedagogy/andragogy

Recommendation 81: Accessibility of digital teaching and learning tools

Postsecondary institutions must ensure that accessibility is at the foundation of the use of digital tools in the practice of Universal Design principles and their application to accessible and inclusive pedagogy/andragogy guidelines.

Timeline: Within six months of regulation being enacted

Recommendation 82: Digital teaching and learning tools barriers

When introducing new digital teaching and learning tools in the practice of inclusive teaching, postsecondary institutions should ensure that they do not create additional barriers to access for students with disabilities, by consulting the committee established in recommendation 14.

Timeline: Within six months of regulation being enacted

Recommendation 83: Usability of digital learning and technology environments

Postsecondary institutions shall ensure the usability of the digital learning environment for all students, including those with diverse information processing styles and sensory/physical attributes through appropriate accessible feedback, tracking and reporting mechanisms.

Timeline: Within six months of regulation being enacted

Theme 6: Accessible content

Recommendation 84: Accessible content, resources, tools and processes

Postsecondary institutions shall support educators by providing them with tools and processes, as well as by offering centralized resources (for example, people, budget, etc.) when sourcing, acquiring, producing and maintaining accessible content.

Timeline: Within six months of regulation being enacted

Recommendation 85: Support for educators and staff

Postsecondary institutions shall include in their Digital Technology Accessibility Plan how they intend to support educators and staff in the provision of accessible content for all program and services.

Timeline: Within six months of regulation being enacted

Recommendation 86: Consulting students

Postsecondary institutions shall consult a body of students with diverse disabilities when acquiring content, or tools for authoring content, to ensure that they are accessible.

Timeline: Within six months of regulation being enacted

Recommendation 87: Accessible PDFs

Postsecondary institutions shall provide all documents in an accessible format. In the case of a PDF, this committee is recommending a phased approach:

• phase 1: postsecondary institutions shall use a PDF document only if an accessible alternative format is also simultaneously available
• phase 2: postsecondary institutions shall provide suitable software and training for the creation of accessible PDFs to the PDF/UA 1/ISO 14289 standard. Following this date, any document provided as a PDF must meet this international standard. However, to phase in this requirement it is expected that postsecondary institutions continue to publish PDF-based digital content to be as accessible as their training and applications permit, even if an accessible alternative is provided. This will lessen any remediation costs if there is a need to go back and ensure that currently produced PDFs meet the PDF/UA 1/ISO 14289 standard. This will also demonstrate the postsecondary institutions’ commitment and progress towards creating accessible PDFs.

Timeline: Phase 1: within six months of regulation being enacted. Phase 2: within two years of the regulation being enacted

Recommendation 88: Software and training for accessible PDFs

Postsecondary institutions shall provide suitable software and training for creation of accessible PDFs.

Timeline: Within six months of regulation being enacted

Barrier area 5: Organizational barriers

The recommendations in this section are intended to reduce, and ideally to eliminate, systemic barriers by developing and implementing organizational policies and procedures that consider the rights and needs of all students with disabilities.

Our recommendations were informed by the collective professional or lived experience of the members of the committee.

The following guiding principles helped to shape all recommendations in this section: 1) postsecondary institutions will create and maintain welcoming and accessible environments that facilitate full participation of all students and 2) students with disabilities will experience barrier-free access to every aspect of their postsecondary experience, including exploration of postsecondary options through application and admissions processes, day-to-day curricular and co-curricular activities, and on to graduation.

Our recommendations fall under the following six themes:

• admission and accommodation processes
• accessibility lens in institutional policies
• handling of accommodation requests
• inclusive teaching and learning environments
• service animals
• business continuity plans

Theme 1: Admission and accommodation processes

Recommendation 89: Transition supports and programming

Postsecondary institutions should seek feedback and recommendations from students with disabilities to help guide the development of transition programming and supports for students during their first year of postsecondary study and at each transition point in their academic journey (for example, experiential learning opportunities, co-op placement, internships, etc.).

Timeline: Within one year of regulation being enacted

Recommendation 90: Admissions processes

Application processes, admission tests, other admission screening and any post-admission tests must meet the following accessibility standards:

• applications, application instructions and information about pre- and post-testing or screening processes will state that accommodations are available and the means by which to access those accommodations
• all admissions documents, including applications and tests, will be readable using assistive technology and all multi-media materials related to the admissions process will be closed captioned, American Sign Language, Langue des signes québécoise, Described and Integrated Described Video where possible and appropriate (French and English). Where these are not available, this will be noted, and alternative options will be offered
• alternative options for accessibility will be readily available as required, including, but not limited to, Braille, large print texts, or reading information aloud to applicants/students

Timeline: Within six months of regulation being enacted

Recommendation 91: Access to disability accommodation information

Postsecondary institutions will provide the public and all applicants for admission with easily located, timely and effective information in accessible formats about the available services, programs and supports for students with disabilities and how to access them. The information should emphasize the need for students with disabilities to alert the postsecondary institution as early as possible about their disability accommodation needs.

Timeline: Within six months of regulation being enacted

Recommendation 92: Documentation policies for academic accommodations

The Ontario government shall consult postsecondary institutions, students with disabilities and other stakeholders to develop common documentation requirements for the provision of accommodations that are consistent with the Ontario Human Rights Commission’s Policy on Accessible Education for Students with Disabilities (March 2018), section 8.7.

Based on these requirements, postsecondary institutions shall develop in a collaborative manner, a consistent and clear set of policies and practices about the nature and extent of documentation required to establish eligibility for academic accommodation. These policies will be readily available in an accessible format on postsecondary institutions’ public-facing websites and all other institutional communication channels.

Timeline: Within six months of regulation being enacted

Recommendation 93: Interim academic accommodations

Postsecondary institutions shall establish a clear practice with respect to providing interim academic accommodations while waiting for further medical or psychological documentation before confirming the accommodations. The practice shall include a statement with respect to the maximum time that interim accommodations will be provided (for example, no less than one semester) that may lead to adjustments to the academic accommodations. The practice on providing interim academic accommodations shall be included in the broader policy on documentation requirements noted in recommendation 92.

Timeline: Within six months of regulation being enacted

Recommendation 94: Full participation

Postsecondary institutions will ensure that students with disabilities are informed, as early as possible in a readily accessible and understandable way, of the institution’s recognition of its duty to ensure that all academically qualified students with disabilities have the right to full participation and full inclusion in all the postsecondary institution’s programming, events, orientations and academic life.

Timeline: Within six months of regulation being enacted

Recommendation 95: Clear policies and procedures

Postsecondary institutions, in collaboration with Ontario government, Colleges Ontario and the Council of Ontario Universities, shall develop, communicate and implement clear policies and procedures and best practice guidelines, that are demonstrably consistent with each other outlining the process by which students with disabilities can access accommodations for academically related learning activities, including, but not limited to:

• classroom
• libraries
• common areas
• online learning tools including accessible software
• tests/examinations
• internships
• practical
• co-ops
• field placements
• apprenticeships
• work integrated learning
• other experiential learning that are part of their academic program of study

These policies, procedures and guidelines should include considerations of disclosure, accommodation, student supervision and assessments. They should also focus on “soft” accessibility features, including but not limited to set up of pods, maximum number of persons in a room, accessible seating, etc.

Institutions shall also develop policies and procedures related to priority access requests (for example, request for priority enrollment in a course, accessible housing placement, etc.) and ensure experiential learning partners are aware of the requirement to accommodate.

Note: given that the Ontario government has mandated that all students should have experiential learning opportunities, we recommend that the government increase the Accessibility Fund for Students with Disabilities to provide funding for accommodations in work integrated learning settings.

Timeline: Develop within six months and implement within two years of regulation being enacted

Recommendation 96: Disability accommodation plans

Postsecondary institutions shall establish and maintain an individualized, dignified and accessible procedure for students with disabilities to request and effectively take part in the development and implementation of plans for accommodating their disability-related needs.

• Postsecondary institutions shall provide information about this procedure to students with disabilities in a readily accessible and timely manner.
• In accordance with the Ontario Human Rights Commission’s Policy on Accessible Education for Students with Disabilities (2018), students with disabilities shall be invited to actively participate in a joint in-person or virtual meeting with Student Accessibility Services to plan for their disability-related supports and accommodations. In the interest of the developmental process, students will be encouraged to participate on their own to assist them in developing their self-advocacy skills. However, if a student with disabilities deems it necessary, they may also decide to involve any support persons and professionals that can assist them in the accommodation planning meeting(s).

Timeline: Within six months of regulation being enacted

Recommendation 97: Disability accommodation caseload – expectations

Student Accessibility Services (SAS) staff should carry a reasonable client load to ensure students will receive appropriate support and timely accommodation. To that end, we recommend that the Ministry of Colleges and Universities undertake a system-wide caseload study, considering the new and changing demands in the provision of education services (Ontario Human Rights Commission, 2018, p. 110), (for example, an increase in the number of students with mental health disabilities requested services) to address trends in required supports. This study will determine:

• if, and how, client load impacts the wellbeing, retention and success of students with disabilities
• current client load levels for SAS staff across the postsecondary sector in Ontario
• what constitutes a reasonable client load for SAS staff providing services to students with disabilities
• if the learning strategist and assistive technology positions developed as a result of the Learning Opportunities Task Force are still able to provide high-impact services and address barriers to learning based on the number of students with disabilities enrolled in services
• the need for additional funding to the Accessibility Fund for Students with Disabilities to achieve reasonable client loads
• how the findings of the autism spectrum transition pilot projects can be rolled out across all Ontario postsecondary institutions to manage staff client load and help students on the autism spectrum transition to postsecondary education and provide the resources and supports needed for students to build their skills

Timeline: Within 18 months of regulation being enacted

Recommendation 98: Disability accommodation caseload – reporting

Postsecondary institutions will monitor and report on the caseload numbers of students with disabilities (as a ratio in comparison to SAS staff) in their Accessibility Fund for Students with Disabilities annual report.

Timeline: Within six months of regulation being enacted

Theme 2: Accessibility lens in institutional policies

Recommendation 99: Accessibility lens

The Ministry for Seniors and Accessibility shall collaborate with relevant stakeholders to develop an accessibility lens for postsecondary institutions to use in all decision making, including but not limited to, developing or revising institutional policies, procedures, processes, programs, social programs and activities.

Stakeholders shall include, but are not limited to:

• students with disabilities
• disability (accessibility) services offices at postsecondary institutions
• accessibility coordinating committees at postsecondary institutions
• College Committee on Disability Issues
• Inter-University Disability Issues Association
• National Educational Association of Disabled Students

All postsecondary institutions shall be required to adopt the use of this accessibility lens in decision making as indicated above.

All postsecondary institutions shall update current accessibility training programs to include training for employees on using an accessibility lens in decision making as indicated in recommendation 22.

The Ontario government shall support ongoing research and development of accessibility tools that effectively identify and remove barriers and publication of research results.

Timeline: Within two years of regulation being enacted

Recommendation 100: Report on training

Postsecondary institutions will report on their use of the accessibility lens and associated training in the multi-year accessibility plan and the annual status reports.

Timeline: Within two years of regulation being enacted

Recommendation 101: Rights and needs of students with disabilities

Postsecondary institutions shall consider the rights and needs of all students with disabilities, regardless of part-time/full-time status or level of study at the postsecondary institutions, when establishing all policies and procedures that could have an impact on students.

Timeline: Within one year of regulation being enacted

Recommendation 102: Alternate program pathways

Postsecondary institutions must consider and offer alternate pathways (such as, program maps) for students with disabilities in academic and professional programs (all programs including certificate, diploma, degree and graduate education) who may need adjustments to time-to-completion (deadlines unless there are bona fide program requirements that would prevent the postsecondary institutions from offering those alternate pathways).

The process for considering the individual needs of students with disabilities with respect to alternate pathways must be communicated clearly and transparently at the pre-admission and admission stages.

These program maps shall be made available in accessible format to all prospective and current students, academic teams and program coordinators, and staff in the offices for students with disabilities.

Timeline: Within one year of regulation being enacted

Recommendation 103: Transparent policies and procedures

All academic and administrative policies and procedures at postsecondary institutions pertaining to students shall be transparent in purpose, written in clear language, and readily accessible by students with disabilities.

Timeline: Within one year of regulation being enacted

Recommendation 104: Accessible procurement policies and procedures

The Ontario government shall create a set of province-wide accessible procurement standards for educational resources to provide guidance to institutions with respect to accessibility principles in the purchase of educational equipment, educational technology, resources and other goods and services within the education context.

Procurement policies must ensure that all purchases made on behalf of the postsecondary institutions are consistent with accessibility requirements. All faculty members and administrative staff must be clearly informed of their responsibilities under the existing Ontario government accessibility laws on procurement.

Timeline: Within two years of regulation being enacted

Recommendation 105: Information and communications standards’ procurement adoption for accessible technology

We agree with and recommend the adoption of the information and communications standards review on Recommendation 14: Procurement for any digital technology purchased.

Timeline: Within one year of regulation being enacted

Recommendation 106: Follow the Integrated Accessibility Standards Regulation, O. Reg. 191/11 (IASR) procurement requirements

Ensure any digital technology acquired otherwise for the purpose of learning must also respect the criteria set in the Procurement section of the IASR General Requirements.

Timeline: Within one year of regulation being enacted

Recommendation 107: Review policies and procedures

All policies, procedures and academic conflict resolution processes for accessibility-related disputes at postsecondary institutions shall be subject to regular review and revision every five years in consultation with the postsecondary institution’s accessibility committee (as mentioned in recommendation 14) and representative students with disabilities at each postsecondary institution, to make sure they:

• are consistent with the act
• reflect the current state of human rights law and policy
• consider changes in organizational structures or resources
• address new human rights issues emerging within the organization
• continue to be effective

Postsecondary institutions shall adopt an academic conflict resolution process for accessibility-related disputes that fall outside the classroom learning environment, for example in research labs, fieldwork or work integrated learning settings.

Timeline: Within one year of regulation being enacted

Theme 3: Handling of accommodation requests

Recommendation 108: Accessibility and accommodation coordinator/champion

To further ensure the effective accommodation of students with disabilities and the entrenchment of accessibility at the front lines, each postsecondary institution shall implement the following:

1. In a small postsecondary institution, without an Accessibility Office, such as one that offers only one or two academic faculties, one senior employee within the organization who reports to the organization’s chief executive officer, dean or director, should be designated as that organization’s accessibility and accommodation coordinator/champion. Their responsibility is to serve as the one-stop point person for students with disabilities seeking accommodations. In cases where this individual does not have adequate background or training, this must be addressed by the postsecondary institution.
2. In a large postsecondary institution such as a college or university that has several faculties or programs, each faculty or program should designate an accessibility and accommodation coordinator/champion with responsibilities to promote academic accommodation and accessibility within that faculty or program. In cases where these individuals do not have adequate background or training, this must be rectified by the postsecondary institution.
3. In large postsecondary institutions with more than one accessibility and accommodation coordinator/champion, all the coordinators/champions should establish a communication network so they can pool expertise and resources. The accessibility committee at each postsecondary institution shall serve a coordinating role for all the designated accessibility coordinators/champions at the postsecondary institution. The designated accessibility and accommodations coordinators/champions shall lead efforts at the organization towards incorporating accessibility into plans and decisions from the top down.

Timeline: Within one year of regulation being enacted

Recommendation 109: Refusal of disability accommodation request

If a postsecondary institution decides not to provide a requested disability accommodation, service or support for a student, or to meet a disability-related need that the student identified, the postsecondary institution will provide verbal and written reasons for that refusal in a timely fashion, normally within three to five business days of formally communicating the refusal to the student.

Timeline: Within one year of regulation being enacted

Recommendation 110: Resolving disability accommodation refusal disputes

Postsecondary institutions must develop an effective and transparent mechanism to resolve disputes that arise in the accommodation process. The mechanism must be a respectful, non-adversarial internal dispute resolution review process for hearing, mediating and deciding on the concerns of students with disabilities. If a student disagrees with any aspect of the postsecondary institution’s decision on a request for accommodation or believes that the postsecondary institution has not provided supports or accommodations to which it had agreed, the student will be informed of the review and dispute resolution process. This tiered review process should include the following:

1. It should be very prompt and conducted expeditiously to ensure that students have the opportunity to complete their course(s) and/or academic program during the relevant enrollment period. Arrangements for a student's accommodations should be finalized as quickly as possible, so that the student’s needs are promptly met.
2. Proposed services, supports or accommodations that the postsecondary institution is prepared to offer should not be withheld from a student pending a review. The student should not feel pressured not to seek a review, lest they be placed in a position of educational disadvantage during the review process.
3. The review process should be fair. The postsecondary institution should let the student know all issues or concerns with the student’s accommodation request and give the student an opportunity to voice their concerns.
4. The initial internal review and dispute resolution process should be led by a person or persons who are as independent and impartial as possible, including but not limited to individuals from an office of human rights or Faculty of Education on campus. They should have expertise in accessible education of students with disabilities. Where possible, they should not have taken part in any of the earlier discussions or decisions at that postsecondary institution regarding the services, supports or accommodations for that student.
5. At the review, every effort should be made to mediate and resolve any disagreements between the student and the postsecondary institution. If the matter cannot be resolved by agreement through this internal process, there should be an option for a qualified mediator who is external to the postsecondary institution to be appointed at no charge to the student, to consider the review. Postsecondary institutions shall identify in advance a mechanism to engage an impartial dispute resolution mediator with expertise in disability and postsecondary education. We recommend that the Ministry of Colleges and Universities establish a list of qualified impartial mediators to assist with this process.
6. If the outcome of the review with an external mediator is that the postsecondary institution refuses the student’s request(s), verbal and written reasons should be given for the decision and the student shall be informed of the option to pursue their concern through the Ontario Human Rights Tribunal.

Timeline: Within two years of regulation being enacted

Theme 4: Inclusive teaching and learning environments

Recommendation 111: Accessible education training

In addition to the training requirements outlined in the Information and Communications Standards sections 21 and 22, postsecondary institutions shall establish policies and procedures to ensure that all full-time, partial load, contract faculty/ instructors and graduate student teaching assistants receive training with respect to accessible, inclusive teaching and learning strategies that are consistent with principles of inclusive, accessible education such as Universal Design in Learning for in person and virtual teaching practices. Postsecondary institutions must develop mandatory training practices that respect their collective agreements and provide fair compensation for all employees not covered by collective agreements. Postsecondary institutions must also develop mechanisms to ensure that teaching faculty who are hired late will receive such training. Postsecondary institutions shall provide evidence in their Annual Status Report to the Ministry of Colleges and Universities that Accessible Education Training opportunities have been provided to all teaching faculty and teaching assistants.

Timeline: Within two years of regulation being enacted

Theme 5: Service animals

Recommendation 112: Service animal definition for postsecondary institutions

We recommend remaining consistent with the existing accessible customer service standards sect. 80.45 (4) b on use, and definition of service animals and refrain from using the term “support animal.” Based on part B of the definition in sect. 80.45 (4) b, an animal is a service animal provided that “the person with a disability provides documentation from one of nine regulated health professionals confirming that the person requires the animal for reasons relating to the disability.”

Further, we strongly recommend that on next review of the customer service standards greater clarification is provided on the definition of service and support animals and the respective roles each play.

Timeline: Immediately upon regulation being enacted

Recommendation 113: Service and support animals policies and procedures

Postsecondary institutions shall establish clear policies and procedures with respect to service animals and support animals. These policies and procedures need to be readily available in accessible format to all students with disabilities. Where a policy exists that addresses pets on campus, the service animals policy shall supersede such a policy to ensure students with disabilities’ full access and integration on campus for students with disabilities.

Student Housing and all student residences must post the policy and make public the process for use of service and support animals in residence.

Timeline: Within one year of regulation being enacted

Theme 6: Business continuity plans

Recommendation 114: Business continuity plans

Postsecondary institutions shall create and/or update business continuity plans with prepared responses to potential disruptions to service delivery, building evacuations, etc., that are dignified and independent for persons with disabilities. Such disruptions can occur due to emergency response situations, labour disruptions, public health restrictions or other disruptions to student education and services. For example, postsecondary institutions may need to collaborate with public transportation services to help ensure that students with disabilities have access to the campus during a labour disruption where picket lines are in force. Postsecondary institutions shall mandate that clear accessible resources and teaching strategies be developed for use in the case of a sudden change to the mode of education due to unexpected disruptions such as those noted above.

These resources will be made available to all teaching faculty and instructors, including but not limited to partial load instructors, part time and sessional faculty, lab demonstrators and teaching assistants. This will ensure that accessibility preparedness is made a priority when planning for emergency situations.

The development of contingency plans must include an expert in accessibility to identify barriers throughout the planning. The plan must incorporate inclusive design principles and include mechanisms to maintain support services for students with disabilities if classes are held during a disruption to standard program delivery. Postsecondary institutions must use an accessibility lens when planning for resumption of studies to ensure that the needs of students with disabilities are considered at both the start and end of disruptions.

Timeline: Within one year of regulation being enacted and updated every three years

Recommendation 115: Disruption impacts

If students with disabilities need to withdraw from their courses to take a disability-related leave due to disruptions of the sort noted in recommendation 114, postsecondary institutions shall:

• establish and communicate a transparent process for students with disabilities (part-time and full-time) that permits students to suspend their studies and to resume their studies after a disruption-related absence
• not require students to reapply to the institution or their program to resume their studies
• facilitate alternate pathways for students with disabilities, both full-time and part-time students, to complete their studies
• not charge an application fee for students with disabilities to resume their studies after a disruption-related absence

Timeline: Within one year of regulation being enacted

Barrier area 6: Social realms, campus life

Campus life involves a wide array of activities and opportunities for all students and provides an additional layer of learning and experience within the postsecondary setting. The "student experience" gained through participating in campus life is now an important piece of a student's skill development and employment outcomes.

Students with disabilities often cannot engage with campus life, in leadership roles that can influence campus decisions, or are restricted in their choice of educational institutions. Additionally, students with disabilities lack accessible, meaningful and predictable programming that facilitates their active participation in the social realm of campus life.

Recommendations in this section are focused upon identifying and removing barriers that hinder students with disabilities from accessing and successfully engaging with campus life outside of the classroom. We specifically focus on accessible events and off-campus activities, student leadership and student engagement. Transition literature, government resources and consultation with provincial colleagues and stakeholders all support the development of recommendations.

We offer recommendations in three key areas:

• accessibility supports
• leadership
• social belonging

Theme 1: Accessibility supports

Recommendation 116: Student government funding for accessible supports (non-regulatory)

Student governments and societies should fund accessibility supports, such as sign language interpreting and attendant services, for students with disabilities to enable their access and participation in non-academic campus life activities that are sponsored by the student governments and student groups.

Recommendation 117: Institution funding for accessible supports

Postsecondary institutions will fund accessibility supports, such as sign language interpreting and attendant services, for students with disabilities to enable their access and participation in leadership roles on governance bodies.

Timeline: Within two years of regulation being enacted

Recommendation 118: Accessible information about supports

Postsecondary institutions will maintain accessible information about on and off-campus accessibility supports and service providers such as attendant services, sign language interpreters, real-time captioning, orientation and mobility trainers for individuals with vision loss.

Timeline: Within one year of regulation being enacted

Recommendation 119: Off-campus services

Postsecondary institutions will identify units or positions responsible for facilitating institutional contact with off-campus service providers, such as those listed in recommendation 118.

Timeline: Within one year of regulation being enacted

Recommendation 120: Attendant services

The Ontario government, in consultation with accessibility stakeholders, will develop a plan to increase the availability and quality of attendant services for postsecondary students with disabilities.

Timeline: Within one year of regulation being enacted

Theme 2: Leadership

Recommendation 121: Governance bodies

Postsecondary institutions will adopt policies and procedures that proactively seek to engage and appoint students with disabilities to their governance bodies.

Timeline: Within two years of regulation being enacted

Recommendation 122: Collect aggregate data

Postsecondary institutions will collect equity representation aggregate data of rates of participation by students with disabilities on all governance bodies such as Board of Trustees/Governors, Senate and student government.

Timeline: Within two years of regulation being enacted

Recommendation 123: Report results

Postsecondary institutions will report the results of recommendations 121 and 122 in the multi-year accessibility plan and the annual status reports, including planned adjustments to enhance the representation of students with disabilities on governance bodies.

Timeline: Within two years of regulation being enacted

Recommendation 124: Accessible sports and recreation programming (non-regulatory)

The Ministry of Colleges and Universities should work with provincial and national professional sport groups for persons with disabilities to create accessible sports and recreation programming to engage postsecondary students with disabilities.

Theme 3: Social belonging

Recommendation 125: Enhance student life and satisfaction

Using the results of measures indicated in recommendation 123, postsecondary institutions will develop new programming or improve existing programming to enhance student life satisfaction for students with disabilities.

Timeline: Within two years of regulation being enacted

Recommendation 126: Student activity fees

Postsecondary institutions that transfer student activity fees to student government and/or student societies will require these bodies to report to the institution administration on their compliance with the act’s regulations in areas of student governance, clubs and groups, activities and events.

Timeline: Immediately upon regulation being enacted

Barrier area 7: Physical and architectural barriers

Recommendations in this section are focused on identifying and addressing barriers to accessibility in the built environment of postsecondary institutions. We took an expansive view of the “built environment,” acknowledging that access should not be limited to buildings but include all the human-made environments in which we live, work and study on a routine basis. In developing our recommendations, we focused on building on existing standards already in use at many postsecondary institutions and shaped our recommendations to address any gaps.

Our recommendations were developed by individuals with lived experience of barriers to the built environment, and those with oversight of providing accessible services and addressing systemic barriers in diverse postsecondary settings. These experiences helped us begin our work from the understanding that our institutions are not universally accessible.

We organized our recommendations across five areas:

• technical requirements – specifications for creating an accessible built environment
• scope – where these standards apply
• maintenance and upkeep – ensuring what is accessible stays accessible
• planning, operations, decision-making, oversight – creating transparency, disability-informed decisions and sustained changes
• awareness, user experience and transparency – improvement projects, signage, training for architects

In focussing on these areas, we sought to bring some clarity to the legislative environment surrounding accessibility standards, to proactively address barriers, and to meaningfully embed the lived experiences of persons with disabilities in a way that honours intersectional identities. By taking this approach we sought to assist postsecondary institutions avoid mistakes, avoid significant costs in the future, and avoid creating long-lasting and hugely detrimental impacts that are difficult to fix.

Theme 1: Technical requirements

Recommendation 127: Minimum accessibility technical specifications

The government shall develop minimum accessibility standards for the built environment of postsecondary institutions, consisting of the technical specifications including, but not limited to those set out in the:

1. Brock University Facility Accessibility Design Standards, 2014
2. The design of public spaces standards
3. Checklist for Making Science Labs Accessible for Students with Disabilities, 2014
4. CNIB Clearing Our Path Guidelines

These requirements should be revised to address considerations for service animals, neurodiversity and sensory sensitivities, and mental wellness. In order to appropriately incorporate these considerations, such standards should be co-designed with persons with lived of experience of these disabilities and organizations that serve in their interest.

Timeline: Within one year of regulation being enacted

Recommendation 128: Adopt minimum accessibility technical specifications

Postsecondary institutions under these standards must adopt the minimum accessibility technical specifications for the built environment.

Timeline: Within 18 months of regulation being enacted

Recommendation 129: Inclusive design principles in policies, practices and procedures

Postsecondary institutions must incorporate robust inclusive design principles into all policies, practices and procedures which relate to the existing built environment and any future development or renovation initiatives. Such a process will involve a thorough review of these policies, practices and procedures to identify and remove any ableist assumptions, and then rebuild these policies with inclusive design principles at the core. Once that has been done, the use of inclusive design principles through the application of an accessibility lens will be a regular part of any built environment policy review process.

Timeline: Within one year of regulation being enacted

Recommendation 130: New built environment accessibility standards

The government shall fully implement recommendation 8 of the 2019 Onley review: “Develop new comprehensive Built Environment accessibility standards” which shall entail:

1. Reviewing and revising the 2013 Building Code amendments for new construction and major renovations
2. Reviewing and revising the design of public spaces standards
3. Creating new standards that apply to retrofitting buildings
4. Report on harmonization process outlined in the Advancing Accessibility in Ontario is a cross-government framework

Timeline: January 1^st, 2023 (in line with planned updates to Building Code)

Theme 2: Scope

Recommendation 131: Upholding accessibility standards in third-party controlled spaces

Postsecondary institutions shall ensure the accessibility technical specifications for the built environment as set out in recommendation 127 are upheld in buildings, venues and spaces the institution uses, leases or is affiliated with, but which may be owned, managed or operated by other organizations or entities. Postsecondary institutions shall review existing agreements and include accessibility requirements in all future agreements. Postsecondary institutions have a duty to inquire about the accessibility of such built environment. If the built environment does not meet these standards, postsecondary institutions shall collaborate with the organizations or entities which own, manage or operate the built environment(s) in question in order to bring the built environment(s) into compliance with the standards.

Timeline: Within 18 months of regulation being enacted

Recommendation 132: Developing guidelines for accessibility standards in third-party controlled spaces (non-regulatory)

We propose that the Ontario government collaborate with Colleges Ontario and the Council of Ontario Universities to develop guidelines on the implementation of recommendation 131. The guidelines shall cover:

• who is responsible in the organizations for upholding the requirements
• how organizations can audit the accessibility of such spaces under recommendation 131
• methods and mechanisms for resolving conflicts between parties

Recommendation 133: Experiential learning off campus

The Postsecondary Education Accessibility Standards for the built environment shall be applied to experiential learning activities that do not take place on the postsecondary institution’s campus (for example, placement host sites), and include all spaces where non-educational services and activities take place on the postsecondary institution’s campus (for example, health services, recreational, civic engagement, common areas in student residences).

1. Postsecondary institutions shall incorporate the technical specifications referred to in recommendation 127 into the criteria and process of finding and matching experiential learning opportunities, such as co-op, apprenticeships or work-integrated learning placements.

Timeline: Within 18 months of regulation being enacted

Theme 3: Maintenance and upkeep

Recommendation 134: Revise maintenance plans and policies

Postsecondary institutions shall audit their built environment and identify all the features that are essential to ensuring and promoting accessible environments. From this review, the institution shall revise maintenance plans and policies to prioritize the timely maintenance and repair of these features to ensure their ongoing use. Such features shall be defined as per the Access and Circulation and Washroom sections of the Brock University Facility Accessibility Design Standard.

Timeline: Within three years of regulation being enacted

Recommendation 135: Track and report spending on maintenance and upkeep

Postsecondary institutions shall track and report the historical (up to five years prior to compliance date for this recommendation) and current spending on the maintenance and upkeep of accessibility features as defined in recommendation 134. This shall be included in all existing internal maintenance reports and be reported on an ongoing basis as part of existing provincial space management reporting systems (for example, Council of Ontario Universities Committee on Space Standards and Reporting).

Timeline: Immediately upon regulation being enacted

Recommendation 136: Funding maintenance and upkeep

The institutions should implement the accessibility lens to consider the impacts of decision making related to budgets on students with disabilities (for example, if a building is not upgraded, how would this impact students with disabilities or how would a reduction of the staff complement for snow removal impact students with disabilities navigating the campus, etc.). Additionally, the Ontario government shall allocate funding to address ongoing efforts to improve physical accessibility and maintenance.

Based on the reports and data received as part of recommendation 135, the Ontario government shall develop expectations for postsecondary institutions to protect a minimum percentage of their facility repair and maintenance budget in order to dedicate it to the maintenance and upkeep of the accessibility features defined in recommendation 134.

The Ontario government shall also develop expectations for postsecondary institutions to protect a portion of their project budget to contribute to the ongoing operation and maintenance of the planned accessibility features when planning and building new environment or facility improvement projects. This portion shall be used as a contingency in the event that these accessibility features are non-operational or fail to meet these standards prior to their anticipated maintenance schedule.

Timeline: Within 18 months of regulation being enacted

Recommendation 137: Procure inventory

Postsecondary institutions shall procure and have a standing inventory of commonly required maintenance and repair materials for accessibility features. Having materials readily available reduces the length of time for replacement or repair if the feature may become, or is, unsafe to use.

Timeline: Within 18 months of regulation being enacted

Recommendation 138: Accessibility metrics

Postsecondary institutions shall develop or incorporate into existing monitoring and response frameworks, metrics specific to the features identified under recommendation 134 as essential to ensuring and promoting accessible environments. Such a framework shall be developed in collaboration with the consulting committee referred to in recommendation 14 and include reasonable response times.

Timeline: Within 18 months of regulation being enacted

Theme 4: Planning, operations, decision-making and oversight

Recommendation 139: Identify barriers and provide accommodations

Postsecondary institutions shall proactively identify barriers in the built environment that cannot be removed or avoided through alternative access due to legal or geographic barriers, such as heritage designation or zoning restrictions. For such barriers, institutions shall identify and prepare accommodations that can be readily accessed by institutional community members and visitors or produce an Equally Effective Access Plan. These accommodations must provide safe, equitable and equivalent access to persons with disabilities in such a way that maximizes accessibility.

Timeline: Within two years of regulation being enacted

Recommendation 140: Renovation, redesign, construction projects

Whenever the postsecondary institution is preparing to undertake a renovation, redesign or construction project, they shall specifically include expectations for the fulfilment of the accessibility standards (as per recommendation 127). This shall be included in all stages of the process including, but not limited to Request for Proposals tender, contracting, project management and feedback, and approvals.

Timeline: Within two years of regulation being enacted

Recommendation 141: Accessibility design experts and consultants

For any proposed building or construction projects, built environment accessibility consultants or firms shall be engaged to review the project and to conduct accessibility audits for compliance to accessibility standards (per recommendation 127). The results and findings shall be reviewed by the postsecondary institution’s accessibility committee (per recommendation 14).

1. The Ontario government shall consult with accessible design experts, persons with disabilities and postsecondary institutions to devise a repository of accessible design consultants, as well as a rubric for how to choose them for design projects. In fulfilling this recommendation, we also propose that the creation of the repository and rubric take into consideration reducing the cost implications to postsecondary institutions from this recommendation and recommendation 142.

Timeline: Within two years of regulation being enacted

Recommendation 142: Construction projects reports

For any proposed new building or significantly renovated projects, built environment accessibility consultants shall track the accessibility deliverables and potential accessibility barriers (as per the criteria in the minimum accessibility technical specifications) in the course of the project and make reports of the findings. These reports shall be provided to the postsecondary institution, members of the institutional oversight/governance process and members of the community for comment. These reports shall receive dedicated time for members of the institutional oversight/governance process to discuss and scrutinize the findings of the report at each stage of the process.

Timeline: Within two years of regulation being enacted

Recommendation 143: Construction projects tax credit (non-regulatory)

We propose the Ontario government develop an enhanced tax credit that is available to private donors to be applied to donations that fund a postsecondary institution’s renovation, redesign or construction project that is fully accessible under these standards. Postsecondary institutions may be eligible for this enhanced tax credit for diverting private bequeaths towards renovation, redesign or construction projects that are fully accessible under these standards.

Recommendation 144: Institution’s capital request expenditure

We propose that the Ontario government implement measures to identify and prioritize the provision and disbursement of public funds to any postsecondary institution’s capital request expenditure for renovations, redesigns or construction projects which comply with these standards or which bring their built environment into compliance with these standards. The postsecondary institution shall provide documentation to the Ontario government that shows the accessibility standards (per recommendation 127) have been met throughout the project.

Timeline: Within two years of regulation being enacted

Recommendation 145: The Role of the consultation committee

The consultation committee referred to in recommendation 14 shall be engaged and regularly consulted throughout the institution’s general operations and management process to provide oversight and advice to aid the institution’s management and upkeep of the built environment. The input of this committee, including the responses to their input, shall be included in all departmental reporting structures.

Timeline: Within two years of regulation being enacted

Recommendation 146: Procuring contractors and vendors

Whenever the postsecondary institution is preparing to procure or renew the services of contractors, vendors, independent agents, etc. for the maintenance of the built environment, the institution shall specifically include expectations for the fulfilment of the accessibility standards. This shall be included in all stages of the process including, but not limited to, tender, contracting, project management and feedback, approvals and performance assessments.

Timeline: Within two years of regulation being enacted

Theme 5: Awareness, user experience and transparency

Recommendation 147: Revised policies and facility accessibility design standards (non-regulatory)

We encourage Colleges Ontario and the Council of Ontario Universities to support their member organizations to develop revised policies and facility accessibility design standards that reflect and align with the new minimum accessibility technical specifications (as per recommendation 127).

Recommendation 148: Training for new and current architects (non-regulatory)

We encourage the Ontario Association of Architects, the Royal Architectural Institute of Canada, the Ontario Association of Landscape Architects and the Canadian Society of Landscape Architects to provide training to newly and currently certified architects about understanding and incorporating the new minimum accessibility technical specifications into designs.

Recommendation 149: Criteria for architects (non-regulatory)

We encourage the Ontario Association of Architects, the Royal Architectural Institute of Canada, the Ontario Association of Landscape Designers and the Canadian Society of Landscape Architects to update all their criteria for membership and certification of architects, no matter what the pathway, to incorporate competencies in accessibility technical specifications and inclusive design principles.

Recommendation 150: Proof of training

As part of their procurement processes for tendering architectural and any other built environment services, postsecondary institutions shall request proof of completion of the training identified in recommendation 148 (or some other proof of competency in the interim). Such proof shall be provided for any professional working with the institution by the vendor for which they are working at the time of bidding for a project. Other proof of competency may include successful completion of the following:

1. Royal Architectural Society of Canada – Introduction to Successful Accessible Design
2. International Association of Accessibility Professionals – Certified Professional in Accessible Built Environments

Timeline: Within three years of regulation being enacted

Recommendation 151: Notice of temporary accessibility barriers

Postsecondary institutions shall provide up-to-date information about any temporary accessibility barriers or service disruptions impacting the accessibility of the built environment. These notifications shall be provided both through institution-specific sources (such as temporary signage or alerts posted to student learning portals or website) and broader public sources (for example, Google Maps). Such notifications shall clearly identify what the barrier is, where it is, the nearest accessible route/service/facility, date and duration of the disruption, and contact information for an ombudsperson or other complaint resolution mechanism. Such notifications must be provided in a timely manner and be in an accessible format.

Timeline: Within six months of regulation being enacted

Recommendation 152: Accessibility during construction

In collaboration with the consultation committee (as per recommendation 14) postsecondary institutions shall proactively devise plans and processes to maintain access during construction projects, both large and small. In addition to the notifications required in this recommendation, such plans and processes must seek to maintain accessibility during construction and, wherever possible, provide an alternative and equal means of access. Once devised, these plans and processes shall be made publicly available and in an accessible format.

Timeline: Within six months of regulation being enacted

Recommendation 153: Signage and wayfinding

Postsecondary institutions shall revise and, where necessary, add more accessible signage and wayfinding resources that make explicitly clear the availability of accessibility features in the built environment in order to facilitate independent navigation and wayfinding. Such information must be prominent and conform with accessibility standards related to information and communications, and the signage section of the Brock University Facility Accessibility Design Standards as per recommendation 127. These wayfinding resources include, but are not limited to:

1. exterior signage and maps (for example, direction posts)
2. interior signage and maps (for example, wing layout)
3. institutional websites (for example, campus maps)
4. any temporary or emergency signage
5. guided campus tours

Timeline: Within six months of regulation being enacted

Recommendation 154: Review the accessibility of the built environment

Postsecondary institutions shall routinely review the accessibility of the built environment. This review will be co-designed with the committee per recommendation 14. The results of the review shall inform planning for concrete next steps for meaningful action. The plan should be reported and updated in line with the institutional multi-year accessibility plan and made publicly available.

Timeline: Within three years of regulation being enacted

Recommendation 155: System-wide improvement plan data

The Ontario government shall gather and collate the improvement plan data from postsecondary institutions in order to monitor and measure postsecondary system-wide accessibility. Such data should be made available to the public and reported on a frequent basis.

Timeline: Within three years of regulation being enacted

Recommendation 156: Improvement projects

Each year, postsecondary institutions shall plan, design and implement projects to improve accessibility in the built environment so that it complies with the standards. The decisions shall be based on areas identified by the plan outline in recommendation 154. Any priority-setting and implementation shall be done in consultation with the committee established per recommendation 14. Postsecondary institutions shall report in the annual status reports on the projects they have undertaken as part of their multi-year accessibility plan, and provide written explanation, should undertaking projects in a given year not be practicable.

Timeline: Within three years of regulation being enacted

Recommendation 157: Promote compliance with the act and Ontario Building Code (non-regulatory)

We encourage the Ontario government to launch initiatives to raise the public profile and promote compliance with the act and Ontario Building Code accessibility standards.

Barrier area 8: Financial barriers

For students with disabilities, the financial barriers they experience are a web of complex systemic issues which can take many forms. In our discussions, we recognized that some financial barriers fell outside the scope of our mandate (for example, Ontario Student Assistance Program (OSAP) reform), and chose to focus our recommendations on four key themes:

• cost differentials
• transparency
• graduate student funding
• intersectionality

These areas were chosen to do two things: first, to “spotlight” issues (such as graduate student barriers and intersectionality) that are often not addressed in conversations around financial barriers and, second, to reduce the manifestation of inequity or potentially exclusionary elements of policy and practice.

Theme 1: Cost differentials

Recommendation 158: Definition of “part-time students with disabilities”

Postsecondary institutions shall adopt the provincial financial aid definition of full-time and part-time status discussed during the 2016 Ontario Student Assistance Program Reform Consultation for students with disabilities for the purposes of accessing financial aid. The definition is included as a reference: a student with a permanent or temporary disability who is enrolled in 40 per cent or more of a full course load will be considered a full-time student for the purposes of applying to the Ontario Student Assistance Program.

Timeline: Within one year of the regulation being enacted

Recommendation 159: Application of “part-time students with disabilities” definition

Postsecondary institutions shall:

1. Create a flexible and confidential process within the institution for disbursement of funds in a timely manner to allow part-time students with disabilities to gain access to institutional scholarships, bursaries, etc. that are currently accessed by full-time students.
2. Regularly measure the effectiveness of these practices by assessing their impact on retention rates and the student experience of students with disabilities.

Timeline: Within one a) and two b) years of the regulation being enacted

Recommendation 160: Higher Education Quality Council of Ontario recommendations – eligibilities, formulae and assessments

We agree with the recommendations in the Higher Education Quality Council of Ontario’s Assessment of Debt Load and Financial Barriers Affecting Students with Disabilities in Canadian Postsecondary Education - Ontario Report (2011), and recommend that:

1. Postsecondary institutions shall reconsider eligibility requirements for institutionally based financial aid specific to students with disabilities so that students with disabilities remain eligible even when they are not eligible for basic provincial or federal assistance (for example, Ontario Student Assistance Program).
2. Where they do not already exist, postsecondary institutions shall adopt eligibility assessments that account for the full impact of a student’s disability(ies) on their financial situation when applying for institutional funding.
3. The Ontario government and postsecondary institutions shall collaborate to improve information sources regarding government subsidies for Indigenous and international students with disabilities, disability assessments, tax credits and other resources for students with disabilities.
4. Where it does not already occur within institutions, postsecondary institutions shall ensure that students with disabilities do not have to pay out of pocket for assessment costs or infrastructure costs associated with disability assessments.

Timeline: Within one year of the regulation being enacted

Recommendation 161: Supplemental health insurance (non-regulatory)

Student unions should create and implement a mechanism to allow part-time students with disabilities to opt into the full-time supplemental health insurance plan to allow students to have the same level of access as full-time students.

Recommendation 162: Differentials in policies and practices

The Ontario government and institutional financial aid administrators:

1. review existing practices in order to determine whether differentials exist that disadvantage students with disabilities.
2. ensure all financial aid policies and practices address gaps and differentials identified in part a) above.
3. shall transparently account for disability-related expenses in financial aid assessments and processes.
4. shall implement a process to allow later payment of tuition fees caused by delays in government funding for disability-related needs without penalty of late payment fees.
5. shall collaborate with appropriate stakeholder groups to regularly measure the effectiveness of practices developed in response to b), c) and d) above on student retention and quality of experience of students with disabilities in postsecondary education.

Timeline: Immediate a), within one year (b-d) and two years e) of the regulation being enacted

Recommendation 163: Institutional fees

Postsecondary institutions shall:

1. review existing institutional fee structures and policies in order to ensure that they are not profiting from the lack of choices and options that students with disabilities experience in paying for institutional services.
2. where necessary, revise and/or adopt policies and practices to ensure that students with disabilities shall not be charged institutional fees incurred due to a disability. For example, a student who needs to defer exams due to hospitalization should not be charged an exam administration fee to defer the exams.

Timeline: Within one year of the regulation being enacted

Recommendation 164: Housing fees

Postsecondary institutions’ Student Housing and Residences Offices shall create a fee schedule that considers disability-related needs related to room assignments. The policy must ensure students are not charged premium rates for costs incurred resulting from a disability (such as, single rooms versus double rooms fees, room for attendant).

Timeline: Within one year of the regulation being enacted

Recommendation 165: Parking Fees

Postsecondary institutions shall create a parking fee schedule that does not charge persons with ministry-issued disabled parking permits premium rates for premium parking locations if students are required to park in these locations due to a disability (for example, underground parking especially in the winter, disabled parking located adjacent to the building).

Timeline: Within one year of the regulation being enacted

Recommendation 166: Ontario Student Assistance Program (non-regulatory)

The Ontario government shall respond to the 2016 Ontario Student Assistance Program Reform Consultation, which included changing the qualification to the following:

• a student with a permanent or temporary disability who is enrolled in 40 per cent or more of a full course load will be considered a full-time student for the purposes of applying through the Ontario Student Assistance Program (OSAP) Application for Full-Time Studies
• review part-time percentage for eligibility

Recommendation 167: Interconnection between financial aid and the Ontario Disability Support Program (non-regulatory)

The Ontario government shall undertake a review of how scholarships and graduate studentships (Teaching Assistant-ships, Research Assistant-ships, Graduate Assistant-ships) relate to both the student financial aid system and the Ontario Disability Support Program, as well as how student financial aid and the Ontario Student Assistance Program intersect, in order to identify barriers faced by students with disabilities in postsecondary education.

Recommendation 168: Interconnection between financial aid and the Ontario Student Assistance Program (2) (non-regulatory)

The Ontario government should develop and implement a plan to address the barriers identified from the review in recommendation 167.

Theme 2: Transparency

Recommendation 169: Transparency of eligibility rules

Postsecondary institutions shall ensure that all financial aid policies, including those at the departmental and faculty level, clearly state the requirements or eligibility rules that have been created for students with disabilities.

Timeline: Within six months of the regulation being enacted

Recommendation 170: Access to financial aid information

Colleges and universities ensure that all institutional financial aid information must be publicly available, easily located, readily accessible, presented in plain language and clear, to be readily available to and understood by students with disabilities.

Timeline: Within six months of the regulation being enacted

Recommendation 171: Central tool (non-regulatory)

The Ontario government shall create and maintain a central tool to inform students with disabilities and financial aid administrators about eligibility guidelines of disability related funding programs (for example, Ontario Student Assistance Program, Assistive Devices Program), applicable restrictions, how the funding programs interact with one another, as well as a timetable or calendar with important deadlines, and set up a notification system for students and other stakeholders to use in signing up for updates, reminders, etc.

Theme 3: Graduate student funding

Recommendation 172: Graduate student financial aid policy

We agree with the recommendations from the National Graduate Experience Taskforce (Understanding Accessibility for Graduate Students with Disabilities in Canada, 2016), and recommend that:

1. The Ontario government and postsecondary institutions shall create policy measures within provincial and institutional financial aid systems that recognize the different experiences and requirements of master’s and PhD student populations and provide funding options to meet their unique needs, with an emphasis on reducing the financial gap for graduate students with disabilities.
2. Postsecondary institutions shall review their financial aid policies around disability related leaves of absence, and, if not already in place, create and implement exceptions regarding leaves of absence in cases of disability-related circumstances.
3. Postsecondary institutions shall review institutional graduate funding packages to include disability-related considerations (for example, leaves, academic employment, funding for disability-related accommodations to travel to academic conferences), where applicable.
4. Postsecondary institutions review their tuition policy and grant graduate students with disabilities eligibility for tuition reduction at the graduate level based on working capacity percentages (full course load equivalency), while being able to maintain full-time status and thus their eligibility to hold awards, bursaries and working opportunities.
5. Regularly measure the effectiveness of these practices by assessing their impact on retention rates and the student experience.

Timeline: Within one year (a-b), within two years (c-d) and within three years e) of the regulation being enacted

Recommendation 173: Dedicated accommodation funding

Postsecondary institutions shall create an institutional framework whereby students with disabilities can access dedicated internal funds to offset their accommodation and unique costs associated with their graduate programs.

Timeline: Within two years of the regulation being enacted

Recommendation 174: Graduate scholarships

We agree with the recommendations from the National Graduate Experience Taskforce (Understanding Accessibility for Graduate Students with Disabilities in Canada, 2016), and recommend that:

1. The Ontario government undertake reviews of the practices and policies of the Ontario Graduate Scholarships program, as well as all other government-funded graduate scholarships, to ensure accessibility and full inclusion of students with disabilities, including students who are enrolled part time as a result of their disability.
2. As part of such a review, the Ontario government shall examine funding and application policies and practices to ensure accessibility for graduate students, including demographic collection methods, application accessibility, equity of information provision, availability of dedicated accommodation funding, and policies around research load, time to completion and leaves.
3. The Ontario government shall ensure that the application forms and processes for the Ontario Graduate Scholarship program and other government-funded graduate scholarships are accessible to students using screen reader and screen magnifier software.

Timeline: Within one year of the regulation being enacted

Recommendation 175: Federally funded graduate scholarships (non-regulatory)

We agree with the recommendations from the National Graduate Experience Taskforce (Understanding Accessibility for Graduate Students with Disabilities in Canada, 2016), and recommend that the Ontario government should:

1. Encourage federal research granting bodies to undertake reviews of the practices and policies of the Ontario Graduate Scholarships program, as well as all other government-funded graduate scholarships, to ensure accessibility and full inclusion of students with disabilities, including students who are enrolled part time as a result of their disability.
2. As part of such a review, federal research granting bodies should examine funding and application policies and practices to ensure accessibility for graduate students, including demographic collection methods, application accessibility, equity of information provision, availability of dedicated accommodation funding, and policies around research load, time to completion and leaves.
3. Encourage federal research granting bodies to ensure that the application forms and processes for graduate scholarships are accessible to students using screen reader and screen magnifier software.

Recommendation 176: Graduate funding guidelines

Postsecondary institutions shall:

1. Review their graduate funding package guidelines and the intersection with accessibility policies (student facing and employee facing) to ensure that graduate students with disabilities are not disadvantaged, either by the impact of a teaching assistant-ship on disability support funding, or by being excluded from a teaching assistant-ship because of their disability.
2. Implement policies to remove the barriers identified in part a) and ensure that graduate students with disabilities are not disadvantaged by the institution’s graduate funding package guidelines.
3. Collaborate with appropriate stakeholder groups to regularly measure the effectiveness of practices developed in response to b) on student retention and quality of experience of students with disabilities in postsecondary education.

Timeline: a) Within one year of the regulation being enacted, b) two years of the regulation being enacted, c) within three years of the regulation being enacted

Recommendation 177: Conferences

Postsecondary institutions shall:

1. Ensure that student financial aid assessments for students with disabilities consider additional disability-related costs incurred while travelling to and participating in academic conferences.
2. Create a centralized “conference accessibility fund” for students to access when needing to travel to academic conferences, for use when advocacy with conference organizers has been exhausted without effect.

Timeline: Within 18 months of the regulation being enacted

Recommendation 178: Time to completion

Where it has been determined that time to completion of a graduate degree for a student with a disability can be extended as an accommodation, postsecondary institutions shall ensure that graduate student financial aid and funding programs are extended to graduate students with disabilities who, for disability-related reasons, are beyond the expected time to completion of their program.

Timeline: Within two years of the regulation being enacted

Theme 4: Intersectionality

Recommendation 179: Intersectionality (non-regulatory)

The Ontario government and postsecondary institutions shall collaborate to ensure that existing and new financial aid policies and practices are reviewed and developed through an intersectional identity lens. These policies should be accessible, written in plain language, and made publicly available via institutional and provincial financial aid websites.

Appendix A: Committee membership

Voting members:

• Tina Doyle (chair), University of Toronto Scarborough
• Tory Bowman, Spinal Cord Injury Ontario
• Sambhavi Chandrashekar, D2L Corporation
• Karen Csoli, Niagara College
• Olga Dosis, George Brown College
• Janice Fennell, Sheridan College
• Ashton Forrest, disability community representative
• Marie-Claude Gagnon, University of Ottawa
• Joseph Roy Gillis, University of Toronto
• Carolyn Hepburn, Sault College
• Jennifer Curry Jahnke, Mohawk College
• Julia Kowal, disability community representative
• Jim Kyte, Algonquin College
• Ainsley Latour, National Educational Association of Disabled Students (Mahadeo Sukhai, Alternate Member)
• Elizabeth Mohler, BALANCE for Blind Adults
• Meri Kim Oliver, Colleges Ontario
• Jeanette Parsons, Inter-University Disability Issues Association
• Anne Pottier, McMaster University
• Ben Poynton, University of Toronto
• Marc Wilchesky, York University

Non-voting members:

• Shirley Carder, Ministry of Colleges and Universities

Appendix B: Glossary of terms and definitions

Ableism

A belief system, analogous to racism, sexism or ageism, that sees persons with disabilities as being less worthy of respect and consideration, less able to contribute and participate, or of less inherent value than others. Ableism may be conscious or unconscious, and may be embedded in institutions, systems or the broader culture of a society. It can limit the opportunities of persons with disabilities and reduce their inclusion in the life of their communities (Ontario Human Rights Commission, 2018).

Ableist

An “ableist” belief system often underlies negative attitudes, stereotypes and stigma toward persons with disabilities and are often based on the view that disability is an “anomaly to normalcy,” rather than an inherent and expected variation in the human condition (Ontario Human Rights Commission, 2016)

Academic journey

The academic journey begins with a student’s first point of contact and continues throughout their experience with that institution.

Academic social life

Students participating with each other in socially based academic activities such as group projects, study groups, class and labs, research and social media specific to courses or programs.

Accessibility

The degree of ease that something (for example, device, service, physical environment and information) can be accessed, used and enjoyed by persons with disabilities. The term implies conscious planning, design and/or effort to make sure something is barrier-free to persons with disabilities. Accessibility also benefits the general population, by making things more usable and practical for everyone, including older people and families with small children (Ontario Human Rights Commission).

Accessibility lens

A tool for assessing how objects, policies, processes and programs impact on persons with disabilities. It is specifically used to identify potential and existing barriers, and corresponding solutions for removing these barriers.

Accessible

When a space or item can be used or experienced by the full range of human diversity with respect to ability, language, culture, gender, age and other forms of human difference in such a way that achieves independence and interdependence, dignity, integration, inclusion and equality of opportunity (Renalds et al. 2010).

Accessible digital content

When students with diverse disabilities can produce/maintain/consume/engage with the content independently and effectively.

Accessible digital learning

When curriculum, instruction, assessment and all related processes such as admission, disability support, etc., happen in ways that students with disabilities can participate independently and effectively.

Accessible digital technology

When technology conforms with the technical accessibility standards as specified by applicable regulations and is functionally usable by students with diverse disabilities independently and effectively.

Accessible event planning tool

A tool that considers all facets of institutionally sanctioned events for potential accessibility barriers, includes guidelines and resources for removing identified barriers, and addresses common barriers, such as providing for the admission and presence of accessibility support providers (for example, attendant services).

The University of Toronto offers a good example of an accessible event planning tool.

Accessible and inclusive pedagogy/andragogy

Embracing diversity in order to meet the varying learning needs and styles of students. For students with disabilities, inclusive teaching practices aim at minimizing the consequences of functional limitations and removing barriers to learning by planning ahead for a variety of learning needs.

Ally/allyship

A member of the dominant group who acts against oppression (Ontario Human Rights Commission, 2013).

Andragogy

The art and science of helping adults learn, focused upon:

1. learning behaviours (degree of self-direction)
2. role of learners’ experiences
3. orientation to learning
4. readiness to learn
5. motivation for learning

Assessment tools

The technological format being used to facilitate the demonstration of skills or mastery of knowledge of a course or program.

Assistive technology

In the digital learning context, assistive technology is any piece of equipment or software program that is used to maintain or improve the functional capabilities of students with disabilities for digital engagement in learning and related activities.

Attitudinal barrier

Behaviours, perceptions and assumptions that discriminate against persons with disabilities. These barriers often emerge from a lack of understanding, which can lead people to ignore, to judge, or have misconceptions about a person with a disability.

Examples of attitudinal barriers include:

• assuming a person with a disability is inferior
• assuming that someone with a speech disorder cannot understand you
• forming ideas about a person because of stereotypes or a lack of knowledge
• making a person feel as though you are doing them a “special favour” by providing their accommodations (Council of Ontario Universities, 2017)

Bona fide academic requirements

Legitimate academic standard or outcome of a program or academic credential (paraphrased from Ontario Human Rights Commission – Policy on Accessible Education for Students with Disabilities, 2018). Established by the Meiorin Test.

Built environment

Includes the human-made space in which people live, work and recreate on a routine basis. This includes the indoor and outdoor facets of:

• sites/grounds
• buildings
• facilities
• paths of travel

As well as the layout and design of their contents, including but not limited to:

• lighting, acoustics, temperature and other environmental components
• furniture
• equipment
• built-in counters, storage and shelving
• accessories such as doorknobs and light switches
• greenery and plants

Taken together, this will facilitate human “interactions that inspire trust and reciprocity among” members of the community (Renalds et al. 2010, p. 68).

Campus life

The full postsecondary education experience, encompassing all academic and non-academic aspects.

Co-designed

Participatory design processes centred around groups of people, particularly ones with lived experience in a particular topic, who collectively contribute to the formulation of a solution to a problem. Co-design is a process which includes idea generation, designing solutions, approvals, implementation and evaluation.

Digital content

Learning material that is produced, maintained, consumed and engaged with online or offline using digital means, including material purchased from vendors, downloaded for cost or free, or shared by educators.

Digital learning

Learning that happens using digital technology and digital content. Learning includes creation and engagement with curriculum, instruction and assessment.

Digital learning environment

The online/blended/hybrid/remote space where learning takes place using digital technology and digital content. While online learning is developed for fully online delivery, remote learning happens when learning designed for classroom is delivered online in times of interruptions to face-to-face class. Blended and hybrid learning allow for both classroom and online learning to coexist.

Digital technology

Includes all software tools and other equipment used in learning such as:

• an integrated learning platform or learning management system with related tools acquired from one source – commercial, open-source, or developed in-house
• additional software tools related to learning purchased, downloaded for cost or free, or developed in-house
• any equipment students interact with in the learning process that is purchased, borrowed, acquired, or developed in-house

Diversity

The presence of a wide range of human qualities and characteristics. The dimensions of diversity may include (but are not limited to) ethnicity, race, colour, religion, age, gender and sexual orientation (Ontario Human Rights Commission, 2013).

Educators

Employees who are involved in program or course design, delivery and instruction, including staff, faculty, teaching assistants and guest presenters of postsecondary institutions.

Equity

Fairness, impartiality, even-handedness. A distinct process of recognizing differences within groups of individuals and using this understanding to achieve substantive equality in all aspects of a person’s life (Ontario Human Rights Commission, 2013).

Equity-deserving group

Those that identify barriers to equal access, opportunities and resources due to disadvantage and discrimination (Canada Council for the Arts, 2020).

The concept of ‘equity-seeking,’ “while well-intentioned, perpetuates a perception of these groups as interlopers. Those on the margins of our community, who feel or are made to feel that they do not belong, deserve equity as a right. They should not be given the burden of seeking it and they should not be made to feel that they get it as a privilege from the generosity of those who have the power to give it, and hence the power to take it back“ (Tettey, W., 2019).

The term represents a shift in language from ‘equity seeking’ to ‘equity-deserving.’

Essential academic requirements

Phrase used by the Ontario Human Rights Commission in Accessible Education for Students With Disabilities to indicate broader expectations of a course/program. The example provided in Section 8.7 suggests that this goes beyond bona fide academic requirements (example is a student is in a hospital and cannot submit an essay by the due date).

Experiential learning

An educational activity facilitated and supported by a college or university through which students learn while doing. Students participate in workplaces, or simulated workplaces, where they are exposed to authentic demands and expectations. The goal of experiential learning (EL) experience is to improve student’s employability and interpersonal skills and to support their transition to the workforce (Ministry of Advanced Education and Skills Development, 2017).

Extracurricular

Activities in which students are outside of the realm of academic education. Whether student or school led, participation is typically voluntary. Participation often helps foster student learning while benefitting well-being by increasing self-esteem, general health and social connections.

Facilities management staff

Employees involved in the management, design and construction of the built environment. This includes, but not limited to, architects, landscape designers, urban planners and interior designers.

Full inclusion

Full and authentic inclusion implies total membership in the postsecondary education community. This means that students with disabilities shall have access to and are encouraged to participate in the same curricular and co-curricular activities as their peers without disabilities.

Inclusive design

Concepts which underlie and support a mindset and practice of “design that considers the full range of human diversity with respect to ability, language, culture, gender, age and other forms of human difference” (Inclusive Design Research Centre, 2020). In line with the Inclusive Design Research Centre, the principles of inclusive designs are:

• recognize diversity and uniqueness
• inclusive process and tools
• broader beneficial impact

Intersectionality

The complex, cumulative way in which the effects of multiple forms of discrimination (such as racism, sexism and classism) combine, overlap or intersect especially in the experiences of marginalized individuals or groups.

Internalized ableism

Personal acceptance, or endorsement of, negative attitudes and beliefs about disability towards self by persons with disabilities. This results in a negative self-concept including but not limited to feeling less than, self-doubt about capability, feeling they are a burden and that they do not belong.

“Internalization occurs through the accumulative, residual and reoccurring experiences of (ableism)…‘the point is oppressed people are routinely worn down by the insidious trauma involved in living day after day in a sexist, racist, classist, homophobic, and ableist society’”(Burstow 2003, 1296 as cited in Campbell, 2008, 155).

Information technology/communications staff

Employees whose responsibilities include communications of Information Technology-related announcements, delivering Information Technology training, supporting user adoption of postsecondary education provisioned Information Technology tools/systems, and providing web publication services to the postsecondary education community.

Media/creative arts staff

Employees whose primary responsibility is to build and create accessible media. This includes, but not limited to, graphic designers, video producers, marketing staff (digital and traditional), web developers and communications.

Microaggression

A statement, action or incident regarded as an instance of indirect, subtle or unintentional discrimination against members of a marginalized group.

Mobility trainers

Specialized individuals that train students who are blind to navigate the physical environment with the goal of independent navigation.

Multi-year accessibility plan and the annual status reports – O. Reg. 191/11, s. 4 (1)

The Ontario government, Legislative Assembly, designated public sector organizations and large organizations shall:

1. establish, implement, maintain and document a multi-year accessibility plan, which outlines the organization’s strategy to prevent and remove barriers and meet its requirements under this regulation
2. post the accessibility plan on their website, if any, and provide the plan in an accessible format upon request
3. review and update the accessibility plan at least once every five years.

Postsecondary education institutions

Every college of applied arts and technology established under the Ontario Colleges of Applied Arts and Technology Act, 2002.

Every university in Ontario, including its affiliated and federated colleges, that receives operating grants from the Ontario government.

It is governed by the Education Act or the Private Career Colleges Act, 2005.

It offers all or part of a postsecondary education program leading to a degree pursuant to a consent granted under the Postsecondary Education Choice and Excellence Act, 2000.

Practicum placement

A practicum placement (sometimes may be called “work placement”) is an undergraduate or graduate-level course, often in a specialized field of study, that is designed to give students supervised practical experience in their field of study.

Pedagogy

The art and science of helping children learn (also, the term used for the scholarship of teaching practice).

Privilege

Unearned power, benefits, advantages, access and/or opportunities that exist for members of the dominant group(s) in society. Can also refer to the relative privilege of one group compared to another (Ontario Human Rights Commission, 2013).

Quality assurance process – colleges

The Ontario College Quality Assurance Service delivers credential validation and quality assurance processes for the public college system in Ontario to assure students, graduates, employers and the public of the quality of the system’s comprehensive programs and services. The Ontario College Quality Assurance Service and its College Quality Assurance Audit Process is recognized by the International Network of Quality Assurance Agencies in Higher Education as being an agency that meets the Guidelines of Good Practice and was developed to ensure quality and continuous improvement in Ontario’s colleges.

The College Quality Assurance Audit Process is an institutional level process that involves the regular and cyclical review of each college’s quality assurance mechanisms. The standards provide the framework for Ontario’s colleges in assessing the extent to which their quality assurance mechanisms meet the established standards. Its purpose is developmental, and its intent is to ensure continual improvement.

Quality assurance process – universities

The Ontario Universities Council on Quality Assurance oversees quality assurance processes for all levels of programs in Ontario’s publicly assisted universities and helps institutions to improve and enhance their programs. Under the Quality Assurance Framework, these institutions have undertaken to design and implement their own Institutional Quality Assurance Process that is consistent not just with their own mission statements and their university Degree Level Expectations, but also with the protocols of this framework. The Institutional Quality Assurance Processes are at the core of the quality assurance process. Furthermore, the universities have vested in the Quality Council the authority to make the final decision on whether, following the council-mandated appraisal of any proposed new undergraduate or graduate program, such programs may commence.

Service animals

The customer service standards under the Accessibility for Ontarians with Disabilities Act, 2005 requires organizations covered by the standards to:

• allow a person with a disability to be accompanied by a guide dog or other service animal on those parts of the premises that the public and other third parties have access to, except where the animal is excluded by another law from the premises
• ensure that other measures are available to enable a person with a disability to access the provider’s goods, services or facilities where a service animal is excluded by another law
• train employees, volunteers and others about how to interact with people using guide dogs or other service animals
• an animal is considered a service animal if either of the below criteria are met:
  • it wears a harness, vest or other visual indicator
  • the person with a disability provides documentation from a regulated health professional

Under the customer service standards there are no restrictions on what type of animal can be used as a service animal. There are various types of service animals besides guide dogs that support people with various types of disabilities, such as: vision loss, hearing loss, Epilepsy, autism, physical disabilities and mental health disabilities. This includes service animals for emotional support.

Social belonging

The experience of connection and relationship with others. Social belonging is a basic human need that is empirically linked to good health, immune function, intellectual performance, well-being and reduced mortality (Oertle and Bragg, 2014). Belonging is strongly linked to persistence for postsecondary education students with disabilities. When they feel like they belong, they feel connected to, included, and accepted by others and the educational institution (Goodenow, 1993). Belonging is measured by the student’s perception of their sense of membership within the institution, their involvement in various settings, and the support they experience (Tinto, 2012).

Social realms

A domain in which social experiences between individuals occur. This includes the context and the opportunity for individuals to experience social connections with each other.

Student

This term includes all individuals enrolled in (or who are considering applying to) a degree or certificate granting academic or professional program, continuing education students, and students in co-op, placements, field experiences, clinical placements, trades, etc.

The teaching assistant role of students is covered within the term ‘educator’ in the Integrated Accessibility Standards Regulation under information and communications standards.

Student leaders

All employees of student unions, and students elected by the student body, to represent them on matters of school programming, policy and campus issues.

Students with Disabilities

All undergraduate and graduate students enrolled in degree or certificate granting academic or professional programs and all continuing education students with diagnosed disabilities.

Work integrated learning

Work integrated learning is a model and process of curricular experiential education which formally and intentionally integrates a student’s academic studies within a workplace or practice setting.

Appendix C: References

Campbell, F. (2008). Exploring internalized ableism using critical race theory. Disability & Society, 23(2), 151–162.

Canada Council for the Arts. (2020). Glossary.

Council of Ontario Universities. (2017). Understanding barriers to accessibility: An educator’s perspective.

Goodenow, C. (1993). The Psychological Sense of School Membership among adolescents: Scale development and educational correlates. Psychology in the Schools, 30(1), 79–90.

Inclusive Design Research Centre. (2020). What is inclusive design?

Ministry of Advanced Education and Skills Development. (2017). MAESD’s guiding principles for experiential learning.

Ontario Human Rights Commission. (2013). Teaching human rights in Ontario – A guide for Ontario schools.

Ontario Human Rights Commission. (2016). Policy on ableism and discrimination based on disability.

Ontario Human Rights Commission. (2018). Policy on accessible education.

Oertle, K. M., & Bragg, D. D. (2014). Transitioning Students With Disabilities: Community College Policies and Practices. Journal of Disability Policy Studies, 25(1), 59-67.

Renalds, A., Smith, T. H. & Hale, P. J. (2010). A Systematic Review of Built Environment and Health. Family & Community Health, 33(1), 68–78.

Tettey, W. (2019). Inspiring Inclusive Excellence - Professor Wisdom Tettey's installation address.

Tinto, V. (2012). Completing College: Rethinking Institutional Action. Chicago: University of Chicago Press.