November 1, 2021

The Postsecondary Education Standards Development Committee is responsible for developing recommendations for accessibility standards for publicly funded postsecondary schools in Ontario. In November 2021, the Committee was seeking public feedback on their initial recommendations report. The proposed postsecondary standards address solutions to identify, remove and prevent accessibility barriers faced by students with disabilities at colleges, universities and vocational institutes. 

Based on March of Dimes Canada’s long history as a service provider and advocate in Ontario, we submitted the following response to help make education more accessible for people with disabilities. 

March of Dimes of Canada welcomes the opportunity to provide input on the initial recommendations for the development of postsecondary education accessibility standards in Ontario. In developing this feedback, we draw on our experience as a major provider of employment services and community-based programs for Ontarians with disabilities, including youth and young adults. We applaud the work of the Standards Development Committee in developing such comprehensive recommendations to address the major barrier areas in post-secondary institutions. 

MODC broadly supports the initial recommendations outlined by the Standards Development Committee. In particular, we welcome the recommendations in the following Barrier Areas:

While MODC endorses the initial recommendations overall, there are some limitations within the proposed regulations that should be addressed to ensure the removal of barriers for students and staff with disabilities in higher education. Our recommendations for strengthening the regulations are outlined below.

Barrier Area 1: Attitudes, behaviours, perceptions, assumptions

This Barrier Area outlines recommendations for addressing barriers resulting from ableism. It is important to note that addressing ableism requires adoption of the social model of disability: that systemic barriers, derogatory attitudes and social exclusion are the true barriers for people with disabilities. While it is clear that the social model is embedded in the Committee’s recommendations, we suggest that the recommendations for transformational leadership and accountability explicitly adopt the social model of disability in order to achieve the intended impact. 

Barrier Area 2: Awareness and training

As noted above, mandatory, standardized training on accessibility is an important step to build awareness among faculty and staff. However, given the focus on addressing ableism, it is important that the content of these trainings is expanded to include not just participants’ rights and responsibilities under current law and accessibility standards, but also a broader focus on inclusivity and inclusive design principles. If the goal is to shift culture at institutions, a broader approach to training is required, to address attitudes and behaviours that exceed a purely a legislative focus. 

As well, while we appreciate that people with lived experience of disability will be consulted in the development of training, it should also be considered if people with disabilities are also best positioned and equipped to deliver the training, given their expertise built from lived experience. 

Lastly, as noted above, the role-specific training for various employee groups is an important step for addressing barriers across the campus experience. Given the context of postsecondary education, it may be worth adding training requirements or guidelines for those who are not full-time or permanent staff, such as volunteers, guest lecturers or contract instructors. 

Barrier Area 3: Assessment, curriculum and instruction

MODC appreciates the robust recommendations regarding removal of barriers in the assessment, curriculum and instruction of postsecondary courses. Teaching styles typically cater to one learning style, which is not accessible to all learners. It is important for educators to teach to different learners’ needs and abilities, and to deliver lessons with examples and context that are relevant to diverse students. 

While developing minimum standards for accessible teaching and learning is important, we would recommend that such government-developed standards and resources are developed in collaboration with people with disabilities. It is also important that these resources are grounded in the social model of disability. 

On the topic of assessments, we welcome the commitment to accessible assessments and the impetus for institutions to link all assessments to essential academic requirements. It is worth adding that as much as possible, testing or assessment methods should be varied to suit the learning styles of any student. If a student can demonstrate their learning in a different way, then that method of assessment should be considered valid.

Barrier Area 4: Digital learning and technology

We appreciate the Committee’s recommendations regarding the creation of an accessible digital learning environment. Importantly, the learning technologies and digital content are not the only technological barrier students with disabilities may face; having entered higher education, they may have new requirements for assistive technology that would support them in their learning and postsecondary experience. Students are often entering school with more basic or less optimized devices. Institutions could play an important role in supporting students with disabilities to identify and access the assistive technology they need to learn, with designated funds to help cover the costs of devices and/or information about community and government resources that can provide funding. 

In addition, on the topic of accessibility training and practice, it should be noted that educational staff should have some level of familiarity with assistive devices in order to be able to provide the support and training that students with disabilities may need in the classroom. 

Barrier Area 5: Organizational barriers

We appreciate the Committee’s recommendations on standardizing documentation policies for academic accommodations. The current practice of providing accommodations to students and staff with disabilities is often rooted in the medical model of disability and can be one of the biggest barriers for students or staff without a formal diagnosis or with poorly understood disabilities. We suggest that the approach to accommodations should be grounded in the social model of disability. Academic accommodations should be reimagined to focus on enabling the individual’s overall participation and inclusion through the removal of barriers, rather than narrowly addressing specific functional needs based on a medical diagnosis.

Barrier Area 6: Social realms, campus life

Recognizing that the social aspects of campus life are an important component of the postsecondary experience, we suggest that recommendations in this Barrier Area should be further articulated. Increased social interaction and participation for students with disabilities is important for addressing the barriers related to ableism in Barrier Area 1. While we understand it is difficult to regulate the activities of all student clubs and activities, we suggest the addition of non-regulatory recommendations related to the activities of all student groups and clubs. 

In addition, on the topic of accessible sports and recreation programming, we suggest also considering the accessibility needs of spectators and attendees (e.g. accessible transportation to off-campus games, accessible seating at stadiums, etc.).

Barrier Area 7: Physical and architectural barriers

March of Dimes Canada welcomes the Committee’s recommendations for addressing barriers to accessibility in the built environment, and in particular addressing gaps in the existing accessibility standards (AODA, Building Code, etc.) pertaining to postsecondary institutions. Importantly, using assistive and accessible technology to complement the built environment should be considered alongside architectural considerations.

One area that may be worth addressing in more specificity is that of student housing and residences. Given the unique nature of a building in which students live, versus one used for work, learning or study, it may be worth enumerating specific requirements for residential buildings. This includes the availability of assistive devices and equipment that can be used to make housing safer and more accessible. Students with disabilities should also be provided with specific guidance and support obtaining accessible on- and off-campus student housing. 

Transportation and commuter students

Transportation must be considered alongside any discussion of physical barriers. If one cannot physically travel to the accessible building, then the accessibility of the building is moot. Notably, there are no specific recommendations regarding accessible transportation in the initial recommendations report, which we suggest is an important consideration, especially as it pertains to commuter students who do not live on or near campus.

Disability/accessibility services

We appreciate the recommendations for increasing support to the services for students with disabilities, as well as maintaining a manageable caseload for student accessibility services staff. However, we believe that the specific services to be provided by the disability or accessibility services office should be further articulated. To ensure the full inclusion and participation of students with disabilities, the disability services office should be providing services that extend beyond academic accommodations and include support with housing, transportation, work placements and employment. 

Meal plans and dietary restrictions

For students that live on campus, meal plans and campus cafeterias are often the primary source of food, especially when most dorm rooms do not have kitchens. Students with disabilities may have unique dietary needs – for instance, a student that uses a feeding tube will require specific foods that can be used with this device, may need access to a refrigerator to store these foods and may need attendant care support to eat. Attention should be given to how students with disabilities’ dietary needs are included on campus. 

Virtual and hybrid learning

While there are robust recommendations regarding the accessibility of digital learning, it is also worth considering how virtual or hybrid learning may be offered as an accessibility support. For students with more complex medical or care needs or students with episodic disabilities, physically attending classes may not always be possible. Offering flexibility and adaptability with a virtual or hybrid learning model can be an accessible alternate for some students. This decision should only be made if this option works best for the student, but it should be made available as an option.