Live Captioning

This guidance describes the university’s approach to captioning during its response to the COVID-19 public health emergency and will be reevaluated as public health and safety directives change.

Questions about this guidance should be directed to the Digital Accessibility Center at accessibility@osu.edu.

  1. Federal and state law, Section 504 of the Rehabilitation Act, the Americans with Disabilities Act and Ohio Administrative Code 4112, prohibit Ohio State from discriminating against people with disabilities in our programs, benefits, and services. Federal law specifically requires that communication provided to people with disabilities be equally effective as that provided to others.

    Ohio State’s policy and standards are designed in recognition of the university’s obligations under applicable state and federal laws. Under the digital accessibility policy accurate captioning of live online events is required by our Minimum Digital Accessibility Standards unless the event has an approved accommodation-based exception request.

  2. For digital (online) events, live captioning is required unless the event has an approved accommodation-based exception
  3. An event can be best described as anything that is not a regular business or class meeting. For example, anything where invitations are being sent, registration is taking place, or participants from outside the university are being invited to participate; especially if events are effectively open to members of the general public.
  4. For online meetings and calls that are a routine part of conducting university business, live captioning is not required unless a participant requests that this be done. An employee needing this accommodation for work and business meetings should contact their HR business partner or the Integrated Absence Management and Vocational Services team within the Office of Human Resources. If in doubt whether a particular meeting is a routine business meeting or event, please contact us for clarification.
  5. Online class meetings for regular academic courses (offerings in the course catalog) do not need proactive live captioning. Enrolled students who require accommodations for their academic coursework can work with Student Life Disability Services to meet their specific needs.

    Note that digital course materials (documents, videos, etc.) are still required to meet the relevant accessibility standards.

  6. Yes in both cases, unless you have an approved accommodation-based exception
  7. Yes, unless you have an approved accommodation-based exception
  8. You may not need to provide live captioning under this scenario, however, operating your event under this assumption requires an approved accommodation-based exception to ensure the appropriate communications and accommodations strategies are in place.
  9. Yes, you can (and should) make an accommodations request part of your registration flow, encouraging requests as far in advance as possible. It is a violation of university policy, state, and federal law to exclude a participant who requests a disability accommodation, even if the university is unable to make the accommodation. No accommodations request should be denied prior to obtaining approval from the Digital Accessibility Center or ADA Coordinator’s office.
  10. We suggest language similar to the following:

    If you require an accommodation such as live captioning or interpretation to participate in this event, please contact Brutus Buckeye at buckeye.1@osu.edu or 614-247-5555. Requests made by (date) will generally allow us to provide seamless access, but the university will make every effort to meet requests made after this date.

    Note that the contact must be someone in the local unit equipped to understand and path the request.

  11. You can add a custom question to the registration form to capture accommodation requests:

    1. Select Webinars from the side menu and click the Topic of the webinar
    2. Under the main details section, select Invitations
    3. Find Approval Options and click the Edit link to the right
    4. Select the Custom Questions tab, then click New Question
    5. Select the Short Answer question type, ensure “Required” is unchecked, and enter your accommodation prompt in the Questions field. Because of character limits in this field the following abbreviated accommodation statement is suggested:
      If you require an accommodation such as live captioning or interpretation to participate in this event, please provide details below. Requests made by (date) will help us to provide seamless access.

    More information on registration form customization can be found in the Zoom documentation.

  12. While captioning may be a sufficient accommodation for many event participants, there are a broad range of disabilities. Captioning (providing alternative text content) can assist a wide variety of users, but it does not accommodate the full spectrum of disabilities.

    If you were to receive a valid accommodation request that was not covered by captioning, you would still need to fulfill that request. For example: sign language may be a more reasonable accommodation than English captions for many in the deaf and hard of hearing community. In this case, you may need to provide sign language interpretation of the event.

  13. A failure to adhere to the policy and exception process for a digital event that seems to be based on poor communications resulting in ignorance of our obligations may result in having the event postponed or cancelled if there is no reasonable way to provide accessibility. Severe or repeated violations will be investigated as potential intentional violation of both the Digital Accessibility Policy (PDF) and our Non-Discrimination / Harassment policy (PDF).
  14. Units should make every effort to plan events with sufficient time to consider all aspects of policy compliance. For time sensitive or last-minute requests, the unit should reach out to the Digital Accessibility Center to discuss the specific situation. Under the current public health emergency, captioning and transcription services generally require 7-10 business days to arrange; however, every effort should be made to fill requests regardless of the time they are received. If you receive a request that you cannot accommodate you must inform the Digital Accessibility Center as soon as you become aware of the issue so that an equitable resolution can be implemented.
  15. An approved exception request is required any time your unit is holding an online event and it will not be captioned as required by university policy and standards. Exceptions may be granted under the following circumstances:
    • The event’s audience is known in advance, and no participants require any captioning accommodations.
    • The event has a robust communications plan for individuals who need accommodations and an approved plan in place to provide them, if needed.

  16. Log in to the exception tracking system and click the “Create New” button. An example exception is also available to review, but please note that your request should be tailored to the unique circumstances of the event.
  17. If the events have similar registration timelines, audiences, and share common accommodation and communications strategies, units may request an exception to cover a set or series of similar events.
  18. Exception requests will need the approval of your Digital Accessibility Coordinator as well as someone within your unit with budgetary authority to approve captioning and other EEAP expenses. Your Accessibility Coordinator will automatically be added as an approver to exception requests – be sure to add any additional approvers prior to submission.
  19. In recognition of the extraordinary circumstances surrounding the COVID-19 public health pandemic, the ADA Coordinator’s Office may be able to provide central support for events that are unforeseeably moved online, that are not otherwise supported by existing revenue, and that are central to the ongoing mission of the university. Requests for this support can be addressed through an accommodation-based exception.
  20. While budget is a concern in any undertaking it is not a sufficient reason for the university to discriminate.

    The ADA Coordinator’s Office is committed to working with all university units to ensure that your events are inclusive and compliant with the institution’s obligations under our policies and applicable state/federal law. If your unit is having issues providing appropriate funding, please reach out to us for further assistance.

  21. While we are unable to endorse any specific vendors, Ohio State has procured captioning services from:
  22. Cost varies based on the length of the event but is generally around $90-$180 per hour.
  23. The university’s obligation is to provide communication to individuals with disabilities that is equally effective as that provided to others; given the complexity and speed at which events are run, generally this task would not be suitable for untrained or inexperienced staff.
  24. There are not currently any university approved tools for this particular use case. We are exploring otter.ai and other similar offerings as potential future acquisitions but we have no timeline or additional information to provide at this time.
  25. Not at this time. No approved tools are available that would meet our standards. This is a rapidly evolving field of technology and we are committed to exploring new tools as they become available.
  26. Yes, unless an approved accommodation-based exception request is obtained.
  27. This depends entirely on the platform you are using to host the event. Zoom, for example, does record captions which can then be retrieved after the fact and downloaded with the rest of the recorded materials. The captions are usually provided as separate files which can be used on the platform that hosts the recorded session. The captions should be edited before the recording is posted: they often contain typographical errors due to the time constraints of real time captioning.

    Note that you should clarify with the captioning vendor that the use of their captions in a recording is allowed – some vendors include contractual restrictions around the use of captions in other media.