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I. INTRODUCTIONA recent study by the PEW Research Center examining the World Wide Web on its twenty-fifth birthday found that eight in ten U.S. adults (81%) used laptop and desktop computers somewhere in their lives-at home, work, school, or someplace else.* 1 In 2012 the global smartphone audience surpassed the 1 billion mark.2 Most people use their computers and smartphones to access the Internet. In 2014, 87% of U.S. adults said they used the Internet compared to a mere 14% of U.S. adults in 1995 reporting that they had access to the Internet.3 The Internet is used to shop, to access news and sports stories, to watch movies and television, to connect with friends and family on social media, and to earn baccalaureate and master's degrees.Commensurate with the growth in Internet usage, higher education is experiencing a growth in online instruction. In 2002, less than one-half of all higher education institutions reported online education as being critical to their long-term strategy; however, in 2013, slightly over 69% percent chief academic leaders asserted that online learning was critical to their long-term strategy.4 The number of students taking at least one online course was 6.7 million in 2013, while 32% of all higher education students take at least one online course.5Some of those 6.7 million students have disabilities. Certainly the Rehabilitation Act of 19736 and the Americans with Disabilities Act of 1990 (ADA)7 improved the accessibility of higher education to persons with disabilities who pursue their education on campus. New buildings must comply with codes designed to remove structural and architectural barriers and to ensure accessibility for students with mobility impairments.8 Offices of disability services at colleges and universities strive to remove other potential barriers to access by providing reasonable accommodations for all qualified students with disabilities.9 Accommodations, for example, may include readers, scribes, alternative format materials (such as handouts and textbooks in Braille), recorders, SmartPens, videos with captions, sign language interpreters, or assistive technology (such as text-to-speech or speech-to-text software).But what about online students with disabilities? Online instruction can be challenging for students with certain impairments.10 Visual impairment can range from complete blindness to being able to read large text on a monitor or having some sort of color vision problem. Auditory impairment can range from having difficulty hearing different frequencies, difficulty hearing over background noise, to complete deafness. Mobility impairments can make it difficult if not impossible to use computer keyboard, mouse, or both. Cognitive impairments can challenge a student's ability to process and understand the content of a web page. This paper will discuss the legislative mandates of the ADA and the Rehabilitation Act,11 examine their application to the online learning environment of higher education, review standards for accessibility in the virtual educational environment and explain ways in which courses can be designed for accessibility.II. THE AMERICANS WITH DISABILITIES ACT OF 1990The ADA aimed to eliminate discrimination against individuals with disabilities so that people with disabilities could be active and productive members of society, undeterred by artificial barriers.12 Concluding that discrimination persisted against individuals with disabilities, which adversely affected both disabled Americans and society as a whole, Congress recognized that:[I]ndividuals with disabilities are a discrete and insular minority who have been faced with restrictions and limitations, subjected to a history of purposeful unequal treatment, and relegated to a position of political powerlessness in our society, based on characteristics that are beyond the control of such individuals and resulting from stereotypic assumptions not truly indicative of the individual ability of such individuals to participate in, and contribute to, society. …
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