H5P and new DOJ regulations

[Delmar Larsen]

Dear Community:

Apologies for cross-listing. I have a quandary that that been plaguing me the past month that I was hoping to get feedback from the community about. 

As many (hopefully most/all) of you know, the new Dept of Justice accessibility guidelines are coming down the pike and set for next Spring. Briefly, these guidelines argue that academia should have all their active content set up to WCAG 2.1 accessibility standards with some added penalties if not. In the time of increased federal scrutiny over academic activities, this is not something that should be ignored. Judith Sebesta gave a nice webinar of this last month for OEG/CCCOER (https://www.cccoer.org/webinar/new-accessibility-requirements-for-web-content-and-mobile-applications-for-public-entities/).

While this has implications for many different aspects of edtech (including anyone creating, distributing, and adoption OER), my immediate question is about H5P interactive assessments. While popular, the vast majority of h5p interactives are not up to WCAG 2.1. While some of the assessments can be with proper workarounds (see our accessibility guide for details - https://studio.libretexts.org/help/h5p-accessibility-guide), most creators don't create WCAG-compliant assessments. Furthermore, many h5p assessments cannot be made WCAG-compliant.

We cannot ignore this issue since campuses are NOT going to encourage or even all the adoption of OER with potential legal penalties from the DOJ. Given the ubiquity of H5P assessments in OER, what are people thinking about doing to address this issue?

These are ideas floating in my head:

1. Excise all h5p assessments from OER to avoid the issue - use a different technology.
   
2. Build a converter to convert the H5P assessments into better tech that can be made accessible with aria and other coding capabilities (e.g., QTI in LMS or other tech like our ADAPT homework system). This would take a bit of effort to do and if QTI is the protocol, then not all problems are possible to be converted since it has limited capabilities.
3. Fork the H5P tech into something separate with control, but them operate outside of the h5p network for updating question types.
4. Work with D2L, the new owner of H5P, to bring those questions that are possible to WCAG-compliance
5. Build an alternative system in the h5p presentation system that provides students with an WCAG-compliant alternative (we do this with ADAPT). This would be painful to implement too.

There are benefits and detraction for each of the options above and none are simple and painless to implement. What is the community thinking about in regards to this specific question. I appreciate any/all feedback. We don't have a lot of time to work around this requirement (Spring of '26).

Regards,

Delmar

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	Delmar Larsen
	Professor and Vice Chair for Undergraduate Affairs
	Department of Chemistry
	University of California, Davis
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	Davis, CA 95616
	+1 (530) 754-9075

	dla...@ucdavis.edu
	http://LarsenLab.ucdavis.edu

	Founder and Director of the LibreTexts Project
	http://libretexts.org
	The Future is Open
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[Judith Sebesta]

Delmar, thank you for sharing my webinar AND your insightful thoughts and questions on this important topic. I’m looking forward to reading the responses. 

Judith 

_________________

Judith Sebesta, Ph.D.

Sebesta Education Consulting LLC

sebestaeducationconsulting.com

Follow me on LinkedIn

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[Charity Davenport]

Hi Delmar! 

H5P is such an important part of easily making content more interactive but also shareable. In my H5P trainings I always tell faculty about the accessibility concerns with H5P and tell them it is important to build a "storyboard" type document in Word so that all the content is in a more accessible format if needed as a backup. I also encourage them to make H5Ps as supplemental materials and knowledge checks and not required to complete a course as well. 

We use Brightspace, and D2L is very committed to accessibility, so my hope would be that they will work with H5P Group to update H5P accessibility as much as possible. That said, I'd go the #4 route and put the pressure on D2L. It would be nice if they made an "H5P" accessibility checker to help H5P creators. 

I do wish there were a way to add documents (ie the more accessible Word document of H5P activities) to H5Ps themselves, or even convert an H5P to Word/ plain HTML page to make a better backup. 

Charity Davenport  

Instructional Technology Specialist (Accessibility) 

Pellissippi State Community College 

Pellissippi Academic Center for Excellence (PACE) 

cdave...@pstcc.edu 

[Delmar Larsen]

Charity:

Thanks for the feedback. This thread in the CCCOER listserv was quiet, but if you want to see a more active discussion on this question check out OEG's Connect: https://connect.oeglobal.org/t/what-are-people-doing-with-h5p-and-new-doj-regulations/7693

There were several recommendations to pursue #4 and I hope to follow through with that when I get some contact information to follow through.

There are different tech approaches that can be made (e.g., not allow h5p interactives to be made unless WCAG compliant). One concern is that the vast majority of existing h5p questions are not accessible (perhaps due to tech and perhaps due to author construction issues). I am concerned about how to update all those questions since they are distributed throughout many different platforms (some centralized, which is easier to address and a lot decentralized, which is a lot hard to address). I feel this will be a mess to untangle although I hope I am wrong.

Cheers,

Delmar

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[Shauna Roch]

Hi Delmar,

Our developer, Jason, has created a tool called the "H5P Description Generator," which can be used to create alt text for H5P interactives. You can find it on the Fanshawe OER Design Studio App Hub. 
Shauna

OER Design Studio, Fanshawe College 

Git Hub Linkhttps://github.com/FanshaweOERDesign

[Elder, Abbey K [LIB]]

Thanks for sharing, Shauna!

We've been following all your team's work on GitHub for a while, and these apps are a great addition to our OER publishing toolkit. 

I think it's a wonderful idea to pursue options like text alternatives and additional exercises to supplement H5P activities rather than to replace them entirely or ban their use. After all, that's what we've done for images, tables, videos and many other problematic media types. Some tables and images cannot be made 100% accessible for all users as they are, so we use alternative text, descriptive text in the surrounding paragraphs, and alternate means of presenting the information to get around that. The same could be done for H5P activity types that cannot be made more accessible. 

Of course, we should still see what we can do to make H5P more accessible when it is possible. I'd love to see alternative text fields incorporated into every H5P activity type that allows for image uploads, for example. Working with H5P to incorporate these updates or forking a more accessible version for open use would be great to see. Will be watching the thread on OEG Connect with interest!

Sincerely, 

--

Abbey K. Elder she, they

Open Access & Scholarly Communication Librarian, Iowa State University

Statewide Open Education Coordinator, Iowa OER

ORCiD: 0000-0003-2289-0166

E: ael...@iastate.edu

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From: 'Shauna Roch' via CCCOER Community Email <cccoer-...@googlegroups.com>
Sent: Monday, June 16, 2025 1:10 PM
To: CCCOER Community Email <cccoer-...@googlegroups.com>
Subject: Re: H5P and new DOJ regulations

 

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