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Live Captioning
This guidance describes the university’s approach to captioning of digital content during its return to normal operations following the COVID-19 public health emergency and will be reevaluated as health and safety directives change.
Questions about this guidance should be directed to the Digital Accessibility Center at accessibility@osu.edu.
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.
For digital (online) events, live captioning is required unless the event has an approved accommodation-based exception.
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.
There are several vendors that provide live captioning services produced using real-time speech-to-text algorithms, without the assistance of a human captioner. Such systems are appealing from a cost and logistics standpoint – but must only be used when appropriate.
Approved automated captioning systems may be used in all but the following circumstances:
- Events that are expected to have more than 200 participants
- Events that communicate critical legal, financial, or medical information
- Events that communicate timely information or that require immediate follow-up action by participants
- Events whose participants are known to require captions or that are focused on disability-related topics
Events using an automated captioning system MUST publish an accommodation statement providing attendees with contact information to request additional captioning or other accommodations. This statement must be communicated to participants, clearly and in an accessible manner, at least 15 business days prior to the event. Suggested language:
This event will be presented with automated closed captions. If you wish to request traditional CART services or other accommodations, 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.
Units using automated captioning for events are required to fund any captioning request they receive. If units wish to have central support this must be approved by the ADA Coordinator’s Office in advance of the event being marketed.
The Digital Accessibility Center is working in close partnership with campus IT units to evaluate captioning technologies. The policy guidance above applies to the following automated captioning tools:
- CarmenZoom automated captioning powered by Otter.ai (the built-in live transcript option)
Yes, unless an approved accommodation-based exception request is obtained.
Our accessibility standards require captions that are accurate. For pre-recorded media these captions should be close to perfect because, unlike live captioning, there are effectively no time constraints.
With this in mind, automated captioning tools may be used as a starting point to generate captions for pre-recorded media, but the captions must be reviewed for accuracy. Any errors in the captions must be corrected prior to use or publication.
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.
Online class meetings for regular academic courses (offerings in the course catalog) do not need to provide 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.
Yes in both cases, unless you have an approved accommodation-based exception.
In general, registered student organizations do not need to provide live captioning for online events and may use automated captioning. However, events held without live captions must:
- Publish an accommodation statement with appropriate contact information as outlined elsewhere in this FAQ
- Publish and/or communicate this accommodation statement to attendees at least two weeks in advance of the event
Student organization events that meet the above criteria may be held without live captioning and do not require an exception. The ADA Coordinator’s Office will organize and fund accommodation requests received for these events. Requests should be forwarded as soon as possible to ada-osu@osu.edu.
The above guidelines only apply to online student events conducted without substantial assistance from the university. Events conducted in close partnership with a university college, department, center, or office must follow the standard guidelines for captioning and accessibility at live events. The campus units that are partnering with the student organization are responsible for compliance with applicable policies and standards.
Substantial assistance may take the form of:
- Funding for event space, technology, presenters, promotion, catering, etc.
- Promotions featuring the campus unit as a partner or sponsor
- Assigning staff to assist with event planning or execution (other than the organization’s advisors)
Yes, unless you have an approved accommodation-based exception.
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.
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.
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.
You can add a custom question to the registration form to capture accommodation requests.
For Zoom Meetings:
- Select Meetings from the side menu and click the Topic of the meeting
- Under the main details section, select Registration
- Find Registration Options and click the Edit link to the right
- Select the Custom Questions tab, then click New Question
- Select the Short Answer question type, ensure “Required” is unchecked, and enter your accommodation prompt in the Questions field.
- Click the Create button, then click Save All.
For Zoom Webinars:
- Select Webinars from the side menu and click the Topic of the webinar
- Under the main details section, select Invitations
- Find Registration Settings and click the Edit link to the right
- Select the Custom Questions tab, then click New Question
- Select the Short Answer question type, ensure “Required” is unchecked, and enter your accommodation prompt in the Questions field.
- Click the Create button, then click Save All.
Because of character limits on custom fields, 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.
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.
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).
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. 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.
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.
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.
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.
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 to the Digital Accessibility Center.
The university has contracted with several vendors to supply live captioning services. The list of captioning vendors can be found on the Digital Accessibility Services site.
Cost varies based on the length of the event but is generally around $90-$180 per hour.
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.
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.